3.4

Object

Representation ID: 7659

Received: 01/09/2021

Respondent: Mr Simon Goodship

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 7757

Received: 22/09/2021

Respondent: Mr Michael Thompson

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 7785

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

3.7. The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

3.8. It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

3.9. It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Object

Representation ID: 7816

Received: 03/09/2021

Respondent: Mr Emilio Meola

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 7855

Received: 03/09/2021

Respondent: Mr Mark Ibbett

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore I do not believe there should be too much dependence on large new settlements Where new settlements are to be built I believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 7961

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements. Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.

The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Support

Representation ID: 8058

Received: 03/09/2021

Respondent: Mr Henry Vann

• Infrastructure requirements must be delivered upfront so that existing residents and incoming residents do not suffer. This includes the delivery of GP surgeries and other health infrastructure, schools and education facilities, green and sustainable transport infrastructure, civic and community infrastructure and on a property-by-property basis, superfast broadband and electric vehicle charging capacity.

Object

Representation ID: 8074

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum wase based on the previous housing needs assessment that proceeded on the basis that the Local Plan 2030 was submitted and examined under the procedures of the NPPF 2012.

The reduction of the plan period from 2035 to 2030 as a result of the lack of deliverability of the Colworth New Settlement and the fact that the plan did not sufficiently address growth associated with the arc led the Inspectors who examined the Plan to include a requirement for a review.

It is therefore clear that the Council needs to consider the review in the context of an elevated housing requirement based upon the Standard Methodology.

If this housing step change is not adequately addressed in the early stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing.

This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption.

Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 8092

Received: 02/09/2021

Respondent: G Morroll

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 8123

Received: 03/09/2021

Respondent: Dr Emma Thompson

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements. Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8162

Received: 03/09/2021

Respondent: Mr Ross Thomson

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements. Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8201

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8260

Received: 03/09/2021

Respondent: Mr Daniel Francis

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 8304

Received: 03/09/2021

Respondent: Miss Erin Francis

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8346

Received: 03/09/2021

Respondent: Mrs K Francis

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 8450

Received: 03/09/2021

Respondent: Mr Theodore Cassell

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements. Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.

The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8519

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

This section of the representations should be read alongside the separate Delivery Assessment included at Appendix 5. This addresses the ability of the Council approach to
maintain a rolling five year supply of deliverable sites (including as part of its proposed use
of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery
Assessment also illustrates that the Council is unable to demonstrate a five year supply of deliverable sites based on its own published position (at a base date of 1 April 2019) or when
this is rolled forward to 1 April 2021.
In summary, the Council’s proposed approach to managing the delivery of housing over the
plan period is unsound. The Council indicates a proposed 20-year plan period (2020 to 2040) for the Local Plan Review. The Local Plan Review must meet minimum annual local housing
need calculated in accordance with the standard method. Planning Practice Guidance ID: 68-031-20190722 answers the question ‘how can past shortfalls in housing completions
against planned requirements be addressed’? and states:
“Where the standard method for assessing local housing need is used as the starting point in forming the planned requirement for housing, Step 2 of the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure. Under-delivery may need to be considered where the plan being prepared is part way through its proposed plan period, and delivery falls below the housing requirement level set out in the emerging relevant strategic policies for housing.”
Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will be relevant to assessing the soundness of the Local Plan 2040. Performance for this period
will therefore be substantially informed by the Council’s current evidence of deliverable supply against the Local Plan 2030 housing trajectory (and extant consents).
The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on a ‘stepped trajectory’ for the plan period to 2030 (retaining an annual requirement of 970
dwellings per annum). The Preferred Options principally rely on large-scale strategic sites
with limited prospects for delivery within five years from adoption (2023 to 2028). The
Council’s supply for this period will therefore also substantially be informed by the Local Plan 2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).
The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed
in the separate Delivery Assessment, demonstrates that these do not achieve an early prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030
Examination relating to constraints to viability and availability of the sites identified,
particularly within the Town Centre.
Regarding Town Centre sites identified in the Local Plan 2030 and the associated longstanding delays to development there is no mention of a Development Corporation in
either the Council’s consultation document or consultation on a Vision for the Oxford-Cambridge Spatial Framework. The Council has previously indicated that this may be the
route to unlocking sites and overcoming barriers to development for which there is currently
no clear solution.
In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary
to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a
stepped requirement appropriate for plan-making’? and sets out:
“A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period. Strategic policy-makers will need to identify the stepped requirement in strategic housing policy, and to set out evidence to support this approach, and not seek to unnecessarily delay meeting identified development needs. Stepped requirements will need to ensure that planned housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may wish to identify priority sites which can be delivered earlier in the plan period, such as those on brownfield land and where there is supporting infrastructure in place e.g., transport hubs. These sites will provide additional flexibility and more certainty that authorities will be able to demonstrate a sufficient supply of deliverable sites against the housing requirement.” (SPRU emphasis)
There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:
 The change in housing requirement cannot be considered significant. The Council was fully aware of these circumstances when the Local Plan 2030 was adopted with the requirement for early review. Planning for a difference in the annual requirement of around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest change in the context of a recently adopted Local Plan that should maintain a minimum rolling supply against the OAN figure
 The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that problem
 The current Local Plan 2030 housing trajectory provides for no flexibility or certainty (particularly given issues with Neighbourhood Plans and Town Centre sites). The Council’s Preferred Options provide no resolution to this.
 The use of a stepped trajectory will not ensure needs are met in full. There will be a substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the latest information regarding supply). A reliance on large-scale strategic sites beyond 2030, for which there is a poor record of success in the borough in terms of timescales and rates of delivery, does not provide a reasonable prospect of development in accordance with PPG ID: 68-019-20190722)
Those issues relating to the current Local Plan 2030 mean that there is no prospect whatsoever that extant commitments and allocations alone would allow the Council to demonstrate a five year supply of deliverable sites based on the calculation of minimum annual local housing need upon adoption of the Local Plan 2030.
Our analysis demonstrates that the Council’s proposed approach to rely on a stepped trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon adoption of the Local Plan 2040 without significant support to prioritise the early delivery of additional sites.

APPENDIX 5 OF ATTACHMENT IS A LOCAL PLAN 2030 DELIVERY ASSESSMENT

Object

Representation ID: 8547

Received: 03/09/2021

Respondent: Mrs Claire francis

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 8619

Received: 13/09/2021

Respondent: Mr Henry Zwetsloot

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 8686

Received: 13/09/2021

Respondent: Mr J Francis

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 8719

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

6.1 This section of the representations should be read alongside the separate Delivery Assessment included at Appendix 5. This addresses the ability of the Council approach to maintain a rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery Assessment also illustrates that the Council is unable to demonstrate a five year supply of deliverable sites based on its own published position (at a base date of 1 April 2019) or when this is rolled forward to 1 April 2021.

6.2 In summary, the Council’s proposed approach to managing the delivery of housing over the plan period is unsound. The Council indicates a proposed 20-year plan period (2020 to 2040) for the Local Plan Review. The Local Plan Review must meet minimum annual local housing need calculated in accordance with the standard method. Planning Practice Guidance ID: 68-031-20190722 answers the question ‘how can past shortfalls in housing completions against planned requirements be addressed’? and states:

“Where the standard method for assessing local housing need is used as the starting point in forming the planned requirement for housing, Step 2 of the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure. Under-delivery may need to be considered where the plan being prepared is part way through its proposed plan period, and delivery falls below the housing requirement level set out in the emerging relevant strategic policies for housing.”
6.3 Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will be relevant to assessing the soundness of the Local Plan 2040. Performance for this period will therefore be substantially informed by the Council’s current evidence of deliverable supply against the Local Plan 2030 housing trajectory (and extant consents).

6.4 The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on a ‘stepped trajectory’ for the plan period to 2030 (retaining an annual requirement of 970 dwellings per annum). The Preferred Options principally rely on large-scale strategic sites with limited prospects for delivery within five years from adoption (2023 to 2028). The Council’s supply for this period will therefore also substantially be informed by the Local Plan 2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).


6.5 The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed in the separate Delivery Assessment, demonstrates that these do not achieve an early prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030 Examination relating to constraints to viability and availability of the sites identified, particularly within the Town Centre.

6.6 Regarding Town Centre sites identified in the Local Plan 2030 and the associated longstanding delays to development there is no mention of a Development Corporation in either the Council’s consultation document or consultation on a Vision for the Oxford- Cambridge Spatial Framework. The Council has previously indicated that this may be the route to unlocking sites and overcoming barriers to development for which there is currently no clear solution.

6.7 In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a stepped requirement appropriate for plan-making’? and sets out:

“A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period. Strategic policy-makers will need to identify the stepped requirement in strategic housing policy, and to set out evidence to support this approach, and not seek to unnecessarily delay meeting identified development needs. Stepped requirements will need to ensure that planned housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may wish to identify priority sites which can be delivered earlier in the plan period, such as those on brownfield land and where there is supporting infrastructure in place e.g., transport hubs. These sites will provide additional flexibility and more certainty that authorities will be able to demonstrate a sufficient supply of deliverable sites against the housing requirement.” (SPRU emphasis)
6.8 There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:

□ The change in housing requirement cannot be considered significant. The Council was fully aware of these circumstances when the Local Plan 2030 was adopted with the requirement for early review. Planning for a difference in the annual requirement of around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest change in the context of a recently adopted Local Plan that should maintain a minimum rolling supply against the OAN figure
□ The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with


the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that problem
□ The current Local Plan 2030 housing trajectory provides for no flexibility or certainty (particularly given issues with Neighbourhood Plans and Town Centre sites). The Council’s Preferred Options provide no resolution to this.
□ The use of a stepped trajectory will not ensure needs are met in full. There will be a substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the latest information regarding supply). A reliance on large-scale strategic sites beyond 2030, for which there is a poor record of success in the borough in terms of timescales and rates of delivery, does not provide a reasonable prospect of development in accordance with PPG ID: 68-019-20190722)
6.9 Those issues relating to the current Local Plan 2030 mean that there is no prospect whatsoever that extant commitments and allocations alone would allow the Council to demonstrate a five year supply of deliverable sites based on the calculation of minimum annual local housing need upon adoption of the Local Plan 2030.

6.10 Our analysis demonstrates that the Council’s proposed approach to rely on a stepped trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon adoption of the Local Plan 2040 without significant support to prioritise the early delivery of additional sites.

Object

Representation ID: 8778

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
Staploe Parish Council believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8813

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8829

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Growth And Spatial Options – Paragraphs 3.4 and 3.5
3.13. The current housing need requirement of 970 dwellings per annum was based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

3.14. It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology. The Council must therefore address the shortfall in this Review. If this is not adequately addressed through the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing.

3.15. It has long been stated that there is a need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the Standard Methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040.

3.16. Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West Rail section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Support

Representation ID: 8858

Received: 29/09/2021

Respondent: Woodland Manor Hotel

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 8942

Received: 01/10/2021

Respondent: Mr James Browning

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 9008

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section of the representations should be read alongside the separate Delivery
Assessment included at Appendix 5. This addresses the ability of the Council approach to
maintain a rolling five year supply of deliverable sites (including as part of its proposed use
of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery
Assessment also illustrates that the Council is unable to demonstrate a five year supply of
deliverable sites based on its own published position (at a base date of 1 April 2019) or when
this is rolled forward to 1 April 2021.

In summary, the Council’s proposed approach to managing the delivery of housing over the
Plan period is unsound. The Council indicates a proposed 20-year Plan period (2020 to 2040)
for the Local Plan Review. The Local Plan Review must meet minimum annual local housing
need calculated in accordance with the standard method. Planning Practice Guidance ID:
68-031-20190722 answers the question ‘how can past shortfalls in housing completions
against planned requirements be addressed’? and states:
“Where the Standard Method for assessing local housing need is used as the starting point
in forming the planned requirement for housing, Step 2 of the Standard Method factors in
past under-delivery as part of the affordability ratio, so there is no requirement to
specifically address under-delivery separately when establishing the minimum annual local
housing need figure. Under-delivery may need to be considered where the Plan being
prepared is part way through its proposed Plan period, and delivery falls below the housing
requirement level set out in the emerging relevant strategic policies for housing.”

Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will
be relevant to assessing the soundness of the Local Plan 2040. Performance for this period
will therefore be substantially informed by the Council’s current evidence of deliverable
supply against the Local Plan 2030 housing trajectory (and extant consents).

The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on
a ‘stepped trajectory’ for the Plan period to 2030 (retaining an annual requirement of 970
dwellings per annum). The Preferred Options principally rely on large-scale strategic sites
with limited prospects for delivery within five years from adoption (2023 to 2028). The
Council’s supply for this period will therefore also substantially be informed by the Local Plan
2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).

The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed
in the separate Delivery Assessment, demonstrates that these do not achieve an early
prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030
Examination relating to constraints to viability and availability of the sites identified,
particularly within the Town Centre.

Regarding Town Centre sites identified in the Local Plan 2030 and the associated
longstanding delays to development there is no mention of a Development Corporation in
either the Council’s consultation document or consultation on a Vision for the Oxford-
Cambridge Spatial Framework. The Council has previously indicated that this may be the
route to unlocking sites and overcoming barriers to development for which there is currently
no clear solution.

In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary
to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a
stepped requirement appropriate for plan-making’? and sets out:
“A stepped housing requirement may be appropriate where there is to be a significant
change in the level of housing requirement between emerging and previous policies
and / or where strategic sites will have a phased delivery or are likely to be delivered later
in the plan period. Strategic policy-makers will need to identify the stepped requirement in
strategic housing policy, and to set out evidence to support this approach, and not seek to
unnecessarily delay meeting identified development needs. Stepped requirements
will need to ensure that planned housing requirements are met fully within the plan
period. In reviewing and revising policies, strategic policy-makers should ensure there is
not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may
wish to identify priority sites which can be delivered earlier in the plan period, such
as those on brownfield land and where there is supporting infrastructure in place e.g.,
transport hubs. These sites will provide additional flexibility and more certainty that
authorities will be able to demonstrate a sufficient supply of deliverable sites against the
housing requirement.” (SPRU emphasis)

There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:
• The change in housing requirement cannot be considered significant. The Council was
fully aware of these circumstances when the Local Plan 2030 was adopted with the
requirement for early review. Planning for a difference in the annual requirement of
around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest
change in the context of a recently adopted Local Plan that should maintain a minimum
rolling supply against the OAN figure
• The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that
problem
• The current Local Plan 2030 housing trajectory provides for no flexibility or certainty
(particularly given issues with Neighbourhood Plans and Town Centre sites). The
Council’s Preferred Options provide no resolution to this.
• The use of a stepped trajectory will not ensure needs are met in full. There will be a
substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the
latest information regarding supply). A reliance on large-scale strategic sites beyond
2030, for which there is a poor record of success in the borough in terms of timescales
and rates of delivery, does not provide a reasonable prospect of development in
accordance with PPG ID: 68-019-20190722)

Those issues relating to the current Local Plan 2030 mean that there is no prospect
whatsoever that extant commitments and allocations alone would allow the Council to
demonstrate a five year supply of deliverable sites based on the calculation of minimum
annual local housing need upon adoption of the Local Plan 2030.
Our analysis demonstrates that the Council’s proposed approach to rely on a stepped
trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon
adoption of the Local Plan 2040 without significant support to prioritise the early delivery of
additional sites.

Object

Representation ID: 9065

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

8.1. Paragraph 74 of the NPPF states that: “Strategic policies should include a trajectory illustrating the expected rate of housing delivery over the plan period, and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites”.
8.2. Despite the requirement of the NPPF, he Draft Local Plan fails to include a housing trajectory so that consultees can comment on the potential timing of housing delivery and the need for supporting infrastructure that needs to be delivered in close coordination. This makes it rather difficult to comment on any delivery assumptions for particular options or sites when the Council has not considered this despite it selected its preferred development options. The Draft Local Plan states:
“As well as setting the housing requirement for the plan period, the plan for submission will also include a trajectory to provide an indication of the timing of the delivery of the housing sites which are identified to meet the target. This will flow from the identification of the plan strategy and work on detailed site assessment and a greater understanding of the timing of the delivery of infrastructure needed to support growth.”
8.3. CPC considers that BBC has failed to appropriately outline how 12,500 homes is deliverable within the plan period and is concerned that there has been insufficient regard to the time taken for new developments to pass through both the planning and construction phases.
8.4. The Lichfields ‘From Start to Finish’ Review Second Edition (2020) and the Letwin Review (2018) highlight the delays with the delivery of large development proposals should not be underestimated as there will be many aspects of housing trajectory that are beyond the immediate control of a local planning authority.
8.5. For larger sites (2000+ homes), the Lichfield Report(2020) outlines an average lead in time of 8.4 years for the average time from validation of the first planning application to the first dwelling being completed. This is based on an average build-out rate of 160 dwellings per annum. On this basis and in the case of Dennybrook, it would take 15.6 years to deliver the figure of 2,500 dwellings set out in the Draft Local Plan. If one were to add the average lead in time to these 15.6 years, it would equate to 24 years from the validation of the first planning application.
8.6. The Letwin Review (2018) is also helpful in outlining a median build-out rate for large sites at 15.5 years.

INCLUDES FIGURE 8.1 TIMELINE FOR THE DELIVERY OF STRATEGIC HOUSING SITES - LICHFIELDS REVIEW (2020)

8.7. This demonstrates that the Dennybrook site and other larger sites cannot be delivered within the stated plan period of 2040 and would not make any meaningful contribution to the Council’s housing needs for many years to come.
8.8. The land promoted for development at Dennybrook is owned by multiple landowners and by our estimate approximately 56 land parcels. This highlights the complexity of the land assembly and delivery issues that the scheme would likely face if it were to be selected. Please note the landownership map is based on an initial assessment of HM Land Registry information and would need to be confirmed by BBC and the landowners as to its accuracy.

INCLUDES FIGURE 8.2 LANDOWNERSHIP PARCELS DENNYBROOK AREA

8.9. BBC’s options presented fail to reflect the lead times associated with various stages of the planning process, including:
• The preparation of relevant Development Plan Documents, Supplementary Planning Documents or Design Codes which aid the delivery of larger sites;
• The Pre-application process, including consultation and engagement with relevant consultees and stakeholders;
• Potential delays in determining Outline planning permissions;
• Approval of Reserved Matters and agreement of relevant phasing;
• The discharge of conditions;
• The preparatory site works, to be informed by site-specific survey recommendations and monitoring before commencement;
• Securing of relevant funding (including S106 and CIL); and
• Delivery of on-site and off-site infrastructure, (associated with larger sites and the creation of a new settlement).
8.10. Delivery will also rely on cooperation with adjoining authorities and liaison and negotiation with statutory consultees. Even the slightest delay in the start date will result in a slower performance, which is then likely to render the assumed delivery rates unachievable.
8.11. Overall, CPC considers that the preparation of a potential housing trajectory is urgently needed, considering a more realistic rate of delivery then the crude assumptions included in the Draft Local Plan. Further evidence gathering should also assess whether BBC should be considering a larger number of smaller sites to meet housing delivery across the Local Plan period.
8.12. The potential for up to 2,500 homes in one location such as Dennybrook and potentially other sites nearby could flood the housing market within one location impacting on market choice and resiliency of the local housing market which will further impact on the ability to delivery homes quickly
8.13. The Council’s poorly thought-out assumptions regarding housing delivery and lack of a housing trajectory result in the Draft Local Plan being currently unjustified and requiring much further evidence looking closely at what could realistically be delivered sustainably in the borough.