Issues and Options

No

2.1 Bedford Borough Council is seeking to satisfy the requirement to instigate the early review of the Bedford Local Plan 2030, as necessitated by Policy 1 of the existing development plan. The 2020 Issues and Options consultation is of very significant importance to ensuring that the Local Plan Review satisfies the requirements of national policy and guidance. 2.2 Policy 1 of the extant Local Plan was framed to ensure that future levels of growth respond to the government’s national policy objectives consistent with Bedford’s role in delivering strategic priorities for the sub-region. The Inspectors’ Report on the examination of the Local Plan makes clear that it (the Local Plan) provides for an annual housing requirement around 30% lower than the current version of the standard method to calculate Local Housing Need (see paragraph 40). 2.3 Transitional arrangements for the Examination of Plans prepared under the requirements of the NPPF 2012, are also cited in the Inspectors’ reasons for accepting a foreshortened plan period to 2030 upon adoption. 2.4 Paragraph 17 of the Inspectors’ Report nonetheless identifies a need to address longer-term strategic priorities, including the Oxford-Cambridge Arc at the earliest opportunity. This will of necessity require a greater degree of engagement on cross-boundary strategic matters, including preparation of Statements of Common Ground and associated outcomes under the Duty to Cooperate. The Inspectors’ Report acknowledges that the less stringent requirements of the NPPF2012 were applicable to the Local Plan in terms of outcomes of engagement (see paragraph 11). 2.5 The Review of the Local Plan also demands an early evaluation of the effectiveness of the current development plan. This specifically relates to the requirement in Policy 1 that the review will secure levels of growth that accord with government policy. A key implication of this relates to the deferral of site allocations to neighbourhood plans. This fundamentally relates to issues of housing land supply and flexibility, including the monitoring of whether the Council is likely to meet even the housing requirement of the Local Plan in full. 2.6 The challenge for the Council in undertaking the Review of the Local Plan 2030 are that issues with its current approach manifest themselves in three main interrelated ways. 2.7 Firstly, the spatial strategy reflects that the current Plan is unable to meet its priorities through strategic options including large-scale sites (including New Settlements) or strategic spatial directions of growth. This makes importing such options into the strategy difficult in the context of meeting the immediate increased requirements from 2020, particularly with options such as New Settlements having been previously rejected. Some of the strategic options identified by the Council therefore only offer a reasonable prospect to meet a proportion of the Council’s requirement in the longer-term. 2.8 These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 2.9 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 supports is below levels previously tested and found to be just as sustainable as other options. This, together with deferral of allocations to Neighbourhood Plans, constrains the Council’s ability to effectively meet its priorities for development through this sustainable ‘dispersed’ strategy. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 8 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 2.10 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local Plan 2030 is not based on a clear understanding of requirements and capacity for growth in individual settlements and instead adopts an arbitrary approach to apportioning requirements. Therefore, while it is evident that the rural area is a suitable location to meet a substantial proportion of the Plan’s increased requirements for development this can only be achieved as part of a detailed review of the settlement hierarchy and provision for development in individual centres. This must be supported by clear policies and allocations within the Plan itself. 2.11 The Council’s consultation documents acknowledge the impact of increases to the annual requirement from the proposed 2020 base-date of the revised plan period. What is apparent from options being assessed by the Council is the scope for ‘supplementary’ allocations where contributions towards the increased requirement from 2020 onwards can be achieved in settlements across the rural area, compared to the current Policy 4S totals. This must be explicitly stated and addressed by the scope of the Local Plan Review, This is because this solution to meeting the Plan’s increased requirement for growth would alter the requirements for general conformity with adopted strategic policies, comprising part of the basic conditions tests that Neighbourhood Plans in the borough need to meet. 2.12 Where the capacity for sustainable development exists, we urge the Council not to impose limits to growth as part of its testing of strategy options or the totals identified for the rural area. Moreover, given the immediate impact of increases to the housing requirement, suitable opportunities for ‘supplementary’ allocations (effectively bridging the gap between the apportionment of growth in the LP2030 and levels of need identified by government policy) should be provided for as allocations rather than being further deferred to the preparation or review of Neighbourhood Plans. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 9 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission a) National Policy and Guidance – Implications for the Review of the Local Plan 2030 i) Plan-Making 2.13 It is helpful to provide a brief overview of policies in the NPPF2019, governing plan-making and central to assessing the soundness of proposals to be prepared as part of the Review of the Local Plan. 2.14 Paragraph 11(a and b) of the NPPF sets out the presumption in favour of sustainable development for plan-making. This establishes that plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change. Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses. It is essential that the options considered as part of the review of the Local Plan seek to fully address these requirements. 2.15 Paragraph 16(c) of the NPPF emphasises that plans must be positively prepared to ensure that they are aspirational but deliverable. Paragraph 20 makes clear that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for development needs (including housing), alongside requirements for infrastructure (including community facilities) and conservation and enhancement of the natural, built and historic environment. This combination of policy requirements is likely to demand an integrated range of approaches, depending on the area’s priorities. 2.16 Paragraph 22 of the NPPF stipulates the requirement for strategic policies to look over a minimum 15-year period upon adoption, in order to incorporate longer-term requirements and opportunities, including major infrastructure investment. Paragraph 23 sets out the importance of plan-making, providing for a clear strategy that ensures bringing forward sufficient land at a sufficient rate to meet needs over the plan period. 2.17 Paragraphs 24 to 27 of the Framework deal with requirements to maintain effective cooperation under the Duty to Cooperate. Ongoing joint working is key to determining how cross-boundary strategic priorities are addressed and setting out where additional infrastructure investment may be necessary. Planning Practice Guidance further sets out the importance of the preparation of Statements of Common Ground to address progress made via engagement. This is central to demonstrating how options have been assessed and that the strategy is deliverable over the plan period (PPG ID: 61-010-20190315) 2.18 Paragraphs 31 to 33 of the NPPF2019 deal with the preparation and review of Plans and specifically the requirement to assess alternative options. Paragraph 33 sets out that the review of Plans “should take into account changing circumstances affecting the area, or any relevant changes in national policy.“ This is clearly reinforced by the requirements of Policy 1 of the Local Plan 2030. In accordance with Paragraph 32 of the Framework preparation of the Plan should seek to achieve net gains for the economic, social, and environmental objectives of sustainable development. 2.19 In relation to identifying land for housing in the context of options identified in the Borough’s consultation proposals paragraph 72 of the NPPF2019 deals with planning for larger-scale development. This stipulates that necessary consideration must be given to requirements for infrastructure and services; joint-working with other authorities (where required); and making a realistic assessment of potential delivery rates, given lead-in timescales for development. This is significant in the context of the Local Plan 2030 having avoided any decisions on strategic locations for growth. 2.20 The requirement for the Review of the Bedford Local Plan 2030, as set out in Policy 1, reflects paragraph 60 of the NPPF2019. This stipulates that strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance i.e. in order to support levels of growth that accord with government BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 10 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission policy. The Council’s consultation document acknowledges the annual requirement of 1,305dpa produced as a result of the current local housing need calculation. However, the scope for the Local Plan Review must also acknowledge Planning Practice Guidance that recognises that the figure produced by the standard method is a minimum starting point (PPG ID: 2a-010-20190220) . As well as considering unmet need from neighbouring authorities guidance also addresses circumstances where actual need is higher than the standard method indicates as well as where a higher requirement might be accommodated (such as because of planning infrastructure improvements). The Council’s consultation documents do not illustrate how issues relating to whether actual need exceeds the figure produced by the standard method will be assessed, nor whether options to support a higher housing requirement will be considered. We reserve our position to comment further on these elements in subsequent stages of consultation, dependent on the Council’s activities to test a sufficiently broad range of alternatives to levels of growth exceeding 1,305dpa. 2.21 We consider that this background to the requirement for the Review of the Local Plan 2030 is not sufficiently acknowledged in the Issues and Options Consultation document. Specifically: • The document includes no reference to the Duty to Cooperate, despite Policy 1 and the Local Plan Inspectors’ Report emphasising the importance of cross-boundary priorities. • That local housing need, as calculated through the standard method, will be treated as a starting point and that opportunities to support a higher requirement will be assessed. • Notwithstanding specific reference to the Duty to Cooperate, the documents also fail to explicitly acknowledge that certain options will require greater impetus than others regarding potential matters including joint-working and infrastructure funding. This should be considered explicitly in terms of the potential timeframes for options to secure sustainable development over the plan period. • The consultation document does not consider issues of flexibility and choice in terms of the scope for the Local Plan Review, which is imperative given the significant increase in the housing requirement to be provided for. It is noted that only the ‘Dispersed Growth’ option is listed as providing for “early delivery of new homes”. • The requirements of NPPF2019 Paragraph 72 should be explicitly acknowledged to frame the Council’s assessment of strategic growth options. ii) Rural Housing and Implications for the Existing Spatial Strategy 2.22 In relation to the spatial strategy of the adopted Local Plan, pp.15 of the Council’s consultation document acknowledges that “growth is directed to the larger villages (except where there are already large-scale commitments or nearby), with more in the key service centres and less in the rural service centres.” This recognition is welcome, but the document goes on to state that this approach to the distribution of growth will not meet development requirements in the longer-term. 2.23 Notwithstanding that the Council is seeking to explore alternative spatial options as part of the Review of the Local Plan, we consider that the consultation document should be explicit that the review will seek to maximise opportunities for growth as part of an overall approach to the distribution of development that has been found to be sustainable. This should acknowledge that: • The figures for individual settlements provided in Policy 4S of the adopted Local Plan are minima and will be reviewed in the period to 2030 and beyond as part of the Review of the Local Plan 2030; BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 11 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission • The settlement hierarchy classification of Rural Key Service Centres and Rural Service Centres will be reviewed as part of the Review of the Local Plan 2030; and • The Council will specifically assess more dispersed options to distribute growth to settlements not currently classified as Rural Service Centres/Key Service Centres – for example other villages with a policy area boundary as encouraged by previous rounds of consultation and the capacity of other settlement is also reviewed. 2.24 These representations provide specific grounds to reflect more clearly each of the components within the scope of the review. Our suggestions accord with national policy for making provision for housing in rural areas. Paragraph 78 of the NPPF2019 states that sustainable development can be achieved through locating housing where this would maintain or enhance the vitality of rural communities. This includes recognition of providing support for local services and supporting the needs of other nearby centres. 2.25 Planning Practice Guidance notes that plan-making authorities should consider the broader sustainability of rural communities and potential benefits to housing affordability when seeking to establish the approach to housing supply in rural areas. This goes on to state: “A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.” (ID: 67-009-20190722) 2.26 The importance of these elements of national policy are reinforced by Paragraph 65 of the NPPF2019 and the requirement for strategic policy-making authorities to set out requirements for designated neighbourhood areas. This should be derived from the overall requirement and reflect the overall strategy for the pattern and scale of development (including any allocations). 2.27 It is not a sound basis for plan-making to suggest that the housing requirement figures and settlements identified for growth in Policy 4S of the Local Plan 2030 will not be reviewed as part of this process. 2.28 The NPPF does not stipulate that requirement figures for designated Neighbourhood Areas should be limited to any existing categories within the settlement hierarchy or adhere to the distribution of growth in the existing development plan. This is inherently logical in terms of considering options for development where, as in the case of the Review of the Local Plan 2030, needs are being considered over a minimum 15-year period. This is particularly relevant to potential requirements for growth in settlements with no figure identified in the current Policy 4S; and for other villages with a Settlement Policy Area Boundary not covered by the existing distribution of growth. iii) Conclusions to Inform the Scope of the Review of the Local Plan 2.29 Taking account of the summary above we consider that the following elements and priorities for plan-making must be clearly set out and explored as part of the scope for the Review of the Local Plan 2030: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). • Reassess the capacity for growth across the settlement hierarchy in the existing Local Plan 2030 alongside a review of the classification on individual settlements (Policy 4S). • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community. • Maximise opportunities to enhance Green Infrastructure and meet healthy BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 12 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission communities objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan. • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period. • Maximise opportunities for suitable, available, and deliverable development in the urban area as part of a composite spatial strategy while acknowledging the constraints to this component of the overall strategy in terms of timeframes and levels of growth. 2.30 The following sections set out the further justification and recommendations for plan-making on how this should be achieved as part of satisfying the legal compliance and soundness requirements for the Local Plan Review. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 13 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission b) Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 2.31 In terms of the testing of options for the distribution of growth it is important to stress that during preparation of the Local Plan the Council only excluded options for higher levels of growth in Key Service Centres and Rural Service Centres purely on the grounds that the level of development was beyond that required by the draft Plan. 2.32 Options deriving a greater proportion of development in these locations had been previously assessed as being some of the most sustainable (see Options 8, 19 and 33 of the Council’s January 2018 Sustainability Appraisal for the Local Plan 2030). This illustrates that in the Council’s consultant’s own view options to meet a higher overall requirement (or provide for an extended plan period) would be “just as sustainable” as the new village option that was selected in January 2018. An outline of options previously tested is summarised in Table 1 below: Table 1. Extracts from January 2018 and September 2018 Sustainability Appraisal list of options Date of SA Scenario New settlements Stewartby brickworks site Land South of Bedford Within and adjoining urban area Group 1 villages Group 2 villages Total dwellings SA January 2018 19 0 0 0 2630 high growth 5100 low growth 225 7955 SA September 2018 13 0 100 0 high growth 2895 high growth 4000 low growth 260 7255 2.33 The Inspectors undertaking the Examination of the Local Plan 2030 identified the subsequent requirement for an immediate review on account of the resulting foreshortened plan period to 2030, and a significant change in circumstances arising from housing needs calculated using the government’s standard method. It is self-evident that the Council’s options for the Review of the Local Plan must incorporate the same (or greater) levels of development identified in previously excluded but sustainable options. 2.34 This is also a logical way to carry forward the approach in the current Local Plan 2030, which recognises the relative importance of the rural area to deliver the Plan’s strategic priorities in terms of overall distribution. This is notwithstanding issues arising from the deferral of site allocations and the constraints imposed by the limited plan period. 2.35 Delivery of growth in the rural area remains of key importance to avoiding negative impacts in sustainability terms and meeting the needs of certain settlements. It is surely the case, given earlier consultations, that if the Plan’s priorities required additional levels of development this could appropriately be delivered in a wider range of settlements (and/or more development where capacity allows in certain settlements). 2.36 Further comprehensive testing of reasonable alternatives that acknowledge the necessity for a flexible spatial strategy and maximisation of opportunities for sustainable development in the rural area to meet the plan area’s strategic priorities must form a key component when preparing the Review of the Local Plan 2030. As per the conclusions in the evidence base for the existing adopted development plan it is our view that: • This would again conclude that distributing a higher proportion of development in the BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 14 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission rural areas at is least equally as sustainable as other options including provision of a New Settlement set out in the January 2018 version of the Regulation 19 Plan; and • It can further be demonstrated that the rural areas (and in-particular Key Service Centres and Rural Service Centres) are capable of sustainably accommodating higher totals for housing than proposed in the adopted Local Plan 2030; and • Sustainable options therefore exist to ensure that the Local Plan seeks to meet needs over a 15-year plan period. 2.37 One further implication for testing levels of growth as part of the ‘Dispersed’ spatial option is that the evidence base for the Local Plan 2030 did not test figures for growth in other villages with a Settlement Policy Area (or ‘Group 3’ villages) such as Felmersham. This is despite such settlements previously being assessed as capable of making a sustainable contribution towards development needs in earlier iterations of the Plan. This view is also consistent with paragraph 65 of the NPPF2019 in terms of the provision of housing requirement figures to all designated neighbourhood areas. Testing of options should therefore assess scope to contribute towards needs for sustainable development across a wider range of centres. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 15 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 2.38 National Planning Practice Guidance sets out that when determining whether policies in existing plans should be updated it is relevant to consider the Council’s housing land supply position and whether issues have arisen that may impact on the deliverability of key site allocations. Both of these aspects are highly relevant in the Borough (ID: 61-065-20190723). 2.39 Appendix 2 of these representations provides further analysis of the Council’s current calculation of a Five Year Supply of deliverable sites and implications for the allocation of sites to accommodate additional housing requirement to be met through the Local Plan Review (i.e. 15,000 dwellings using the current calculation of local housing need). 2.40 Table 2 below illustrates that when committed supply against the requirements for growth to be provided for through the Review of the Local Plan 2030 are understood in the context of forecast supply a substantial requirement for allocations exists in the period 2023-2030. This equates to a further 3,341 units to be provided to meet housing needs identified by the government’s current standard method in the period 2024 to 2030, in addition to a small shortfall to be provided against adoption of this requirement for the proposed plan period from 2020. Table 2. Contribution of Forecast Local Plan 2030 Supply Towards Housing Requirement Options based on Local Housing Need Additional Allocations Required (by breakdown of Plan Period) Total Additional Allocations Required Annual Requirement 2020-2023 2024-2030 2030-2040 2040-2045 2020-2040 2020-2045 Committed Supply (based on Local Plan 2030 Housing Trajectory) 3,487 5,794 1,647 0 Supply vs Requirement (Future Plan Period) Local Housing Need - Current Standard Method 1,305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1,153 28 -2,277 -9,883 -5,765 -12,132 -17,897 2.41 The figure of at least 3,341 units broadly determines the scope for ‘supplementary’ allocations beyond the levels of development identified in Policies 3S and 4S of the current Local Plan. It is essential that the Review of the Local Plan adopts a positively prepared approach to providing for the apportionment of additional requirements for growth and does not impose arbitrary caps to development in individual settlements as well as reflecting those centres where capacity is greatest. The ability of suitable, deliverable allocations to meet increased requirements in the period to 2030 should be considered favourably in the context of assessing site options and site selection. 2.42 The Council’s most recent ‘5 Year Supply of Deliverable Housing Sites’ Report highlights three key reasons why choice and flexibility in supply as part of preparation of the Local Plan Review is critical. This aligns with broader concerns regarding the effectiveness of the existing development plan and conclusions that undermine the Council’s current claimed BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 16 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission supply of deliverable sites: • As a result of the approach to managing supply in the adopted Plan a surplus in delivery for the period 2015 to 2019 means the Council is seeking to provide for reduced annual five year requirement in order to maintain supply in excess of five years (798dpa vs 970dpa). • Furthermore, the Council’s accounting for oversupply exceeds the allowance proposed by the Inspectors, which would factor this over the remaining plan period (798dpa vs 918dpa) (see Inspectors’’ Report paragraphs 116 and 117). • The Council now acknowledges that it regards none of the sites allocated via the Local Plan 2030 or proposed for allocation in Neighbourhood Plans to be prepared (where permission is not already in place) are to be treated as deliverable. 2.43 Table 3 below summarises the impact of these elements of the calculation (in terms of forecast supply and the management of oversupply) of housing land supply using the adopted Local Plan 2030: Table 3. Comparison of Calculations of the Five Year Requirement and Housing Land Supply Based on Bedford Local Plan 2030 Requirement Council's Update Inspectors' Method for Oversupply No Oversupply No. of Dwellings No. of Dwellings No. of Dwellings Local Plan Requirement 14550 14550 14550 Annual Requirement 970 970 970 5 Year Supply Requirement 2019-2024 (970 x 5) 4850 4850 4850 Requirement 2015 to 2019 3880 3880 3880 Completions 2015 to 2019 4,928 4,928 4,928 Shortfall / Oversupply 2015 to 2019 -1048 0 Residual Local Plan Requirement 9,622 Annual Requirement with Adjustment for Oversupply 760.4 875 970 Requirement incl. Shortfall 3802 4374 4850 5 year supply requirement (2019-2024) including 5% buffer 3992 4592 5093 Annual supply required 798 918 1019 Supply 4,593 4,593 4,593 Difference 601 1 -500 5 year housing land supply position 5.75 5.00 4.51 2.44 The Review of the Local Plan 2030 should therefore acknowledge its key role in ensuring the Borough Council’s ability to provide choice and flexibility in supply. This role will increase further in the event of any further delays to the preparation of Neighbourhood Plans or delivery of other allocated sites (including Town Centre sites) but is in any event necessitated by the increase in the housing requirement derived through national policy. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 17 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission d) Impact of Government Consultation on Proposed Planning Reforms 2.45 Appendix 3 of these representations considers the potential implications of the government’s ‘Planning for the Future’ White Paper in the context of the scope for the Local Plan Review. In summary, the contents of the White Paper comprise consultation proposals only and are of no material weight in terms of approaching the requirements of plan-making, however we reserve the right to comment further in due course. 2.46 It should be noted, however, that where page 16 of the Council’s consultation document refers to pending details of the government’s proposed revisions to the standard method to calculate local housing need this is on the basis of indicating a potential reduction in the housing requirement to 800 homes per annum. While the Council states this reflects uncertainties with the most recent 2018-based household projections the government has reasserted its commitment to delivering a figure of at least 300,000 homes per annum across England. 2.47 The government’s consultation proposals on a revised approach to calculation of the standard method achieve a total of 337,000 dwellings per annum, including an assessment of need equating to 1,153 dwellings per annum in Bedford Borough. This is substantially greater than the lower end of the range indicated in the Borough’s Consultation Document. We therefore consider that the Council’s indicative suggestion for a ‘lower end’ housing requirement has no basis in delivering a sound outcome against the requirements for the Local Plan Review, as stipulated by Policy of the Local Plan 2030.

3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: • The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options. • Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans. • The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth. 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at settlements including Sharnbrook and Oakley than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 3.7 These components of an appropriate strategy should complement an aspirational but realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 3.8 We have identified three main elements of the Council’s proposed Vision where amendments BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 19 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”

I agree with this plan period

3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: • The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options. • Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans. • The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth. 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at settlements including Sharnbrook and Oakley than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 3.7 These components of an appropriate strategy should complement an aspirational but realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 3.8 We have identified three main elements of the Council’s proposed Vision where amendments BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 19 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”

I agree with this plan period

4.1 The proposed plan period of 2020 to 2040 is accepted in principle and the Council acknowledges that this would satisfy the requirements to provide for a minimum 15-year period upon adoption. The Council also proposes to incorporate years from 2020 into the proposed plan period, which captures the years during which the Local Plan Review is to be prepared, examined, and adopted. This aspect is supported. 4.2 Planning Practice Guidance in relation to monitoring of housing completions against planned requirements sets out that: “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.” (PPG ID: 68-031-20190722) 4.3 This is relevant as the Council proposes to base the calculation of local housing need on the ‘current year’ of 2020. In practice this means that where supply falls below the proposed requirement (i.e. 1305 based on the most recent calculation) this shortfall is incorporated in provision made within the Review of the Local Plan 2030 upon adoption. 4.4 This would represent a positively prepared and effective approach to plan-making and would, in effect, ‘make up the difference’ between local housing need as calculated by the government’s standard method and the objectively assessed need of 970dpa used to inform the adopted Plan. The Council’s most recent ‘5 Year Supply Deliverable Housing Sites Report’ (June 2020) forecasts 2,758 completions for the period 2020/21 to 2022/23 i.e. an under-delivery of shortfall of 1,157 units to be addressed upon adoption. 4.5 Within this context and given the background to the adopted Local Plan 2030 it is important that options for the length of the plan period do not facilitate any further delay to meeting needs in full. These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options for large-scale development, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 4.6 In accordance with Planning Practice Guidance the approach adopted by the Council should support the prioritisation of sites that can be delivered early in the plan period, including those where supporting infrastructure is in place (ID: 68-021-20190722). Likewise, it may not be appropriate to consider a longer plan period or anticipate a substantial contribution towards requirements from options with no reasonable prospect for development within the 15 year minimum plan period.

Brown – Urban based growth , Yellow – A421 based growth , Grey– Dispersed growth

5.1 The context for the Council’s Review of the Local Plan 2030 is substantially broader than the relatively narrow scope of objectives and options for distribution that the Inspectors accepted as reasonable for the purposes of the plan period to 2030. 5.2 Paragraph 48 of the Inspectors’ Report confirms that options for spatial distribution to meet requirements beyond 2030 did not require explicit consideration. For the same reason, reasonable alternatives for the scale and distribution of growth were constrained to within +/- 20% of the selected requirement that the Council has provided for as a result of the NPPF2012’s transitional arrangements for housing need. 5.3 In terms of the options for the Local Plan Review the Council must ensure that this format of constraints to the alternatives being assessed are removed in their entirety. This will provide for substantially more flexibility in terms of meeting a broader range of objectives over the plan period. This broader scope accords with the Council acknowledging that an appropriate spatial strategy is likely to combine a number of the options identified. 5.4 The background to preparation of the Local Plan 2030, including adopting a foreshortened plan period, is relevant to the identification of options for the Review. This reflects constraints to strategic growth options acknowledged as part of the Local Plan 2030 process. 5.5 The Borough Council has no recent track record of outcomes under the Duty to Cooperate for exploring meeting needs elsewhere or at the administrative boundary with other neighbouring authorities (save for the Wixams). This should frame the Borough Council’s understanding of whether large-scale strategic options are justified or would make an effective or positively prepared contribution towards meeting needs in the early part of the plan period. 5.6 During the Examination of the Local Plan 2030 DLP argued on behalf of numerous clients that the submission version of that Plan was a substantial departure from previous iterations. This was reflected in its increased proportion of growth in the rural areas, whilst removing altogether the strategic priority of providing for a New Settlement as well as acknowledging constraints to the rate of development in the urban area. 5.7 These arguments were in effect accepted due to the requirement for an immediate review under Policy 1. Furthermore, the Review of the Local Plan 2030 must ensure that the priorities of the current plan remain a key part of the objectives. This includes addressing delays to bringing forward allocations in the rural area and rates of development in the Town Centre as well as meeting an increase in current and future needs from 2020. It is therefore not a logical conclusion that certain options identified by the Council represent reasonable alternatives to meeting the Plan’s overall objectives and requirements in the early part of the plan period, albeit they may make a greater contribution in later years. 5.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main following elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 5.9 Further initial observations on these components of an appropriate spatial strategy as well as observations on the potential for other options to make a longer-term contribution towards development needs are set out below and should be read alongside our representations as a whole. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 22 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission a) Summary of Conclusions on Preferred Spatial Distribution Options 5.10 Grey– Dispersed growth – Further substantial testing of this spatial option is self-evidently critical to the soundness of the Review given its importance to delivery of the strategic priorities of the current Plan. The Council recognises the benefits of early delivery, which is essential to meet the increased annual requirement for development in the period 2020-2040, associated with this option. This means that meeting additional requirements for development through the Local Plan Review cannot rely on options where delivery is deferred to 2030 or beyond. 5.11 This option is consistent with a number of key elements of national policy that should be considered when reviewing existing policies (including flexibility and maintaining housing land supply). This option would have to fulfil and maximise the overall potential for sustainable development in the rural area that was curtailed by the timeframe and under-provision against full housing needs in the adopted Local Plan 2030. This can be achieved through a review of the classification of the settlement hierarchy and the distribution of requirements based on updates to Policies 3S and 4S in the Local Plan 2030. 5.12 Brown (Urban-based) – We support that the testing of options needs to differentiate Town Centre locations with sites across the borough and at the urban edge. Noting constraints to the existing strategy, increased reliance on the Town Centre would lead to potentially exacerbating existing constraints to timeframes and rates of development in this location. The Local Plan 2030 does not maximise opportunities for small-scale extensions to the urban area, which can be sustainably incorporated into the spatial strategy while the Council assesses other longer-term strategic options. 5.13 Yellow – A421 based growth – It is recognised that the list of advantages associated with this option seek to and capitalise on committed and planned infrastructure improvements including works to the A421, Black Cat and Caxton Gibbett roundabout. 5.14 The improvements complement longer-term strategic objectives for planning across the sub-region so that this option is capable of supporting further large-scale growth in the future. Critically, options to increase levels of sustainable development exist based on the characteristics of existing settlement and land use patterns across the A421 corridor. This avoids some of the constraints to other strategic options, in terms of scope to deliver needs throughout the extended plan period. This option could not, however, deliver the Plan’s increased requirement for development in its entirety. 5.15 It is noted, however, that these more immediate opportunities are focused upon the capacity for growth within the existing settlement hierarchy, including the Key Rural Service Centre of Great Barford and the Rural Service Centre at Roxton. Opportunities to maximise the benefits of sustainable development are thus focused upon a review of the distribution of growth provided for by Policy 4S of the current Local Plan. To this extent we would identify that this spatial option is not viewed in isolation but is considered alongside a review of the capacity for growth in other Key Service Centres and Rural Service Centres based on their alignment with the Plan’s wider priorities (for example the requirements for development in Sharnbrook and Oakley). b) Summary of Conclusions for Alternative Spatial Distribution Options 5.16 For the avoidance of doubt, it is not the purpose of these representations to state that reasonable alternatives for further testing do not exist within the other spatial distribution options identified in the Council’s consultation document. However, the Council’s own evidence expresses a significantly greater range of uncertainties and potential disadvantage to the remaining Orange, Red and Pink spatial options. Each of these is associated with spatial strategy options primarily focused on planning for larger scale development. In terms BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 23 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission of the potential for these options to contribute towards the Plan’s objectives these options should be considered alongside paragraph 72 of the NPPF2019 and in-particular part (d) requiring consideration of likely delivery in the plan period. 5.17 Amongst the disadvantages associated with the remain spatial options, the Council lists the following: • Other locations would miss the benefits associated with growth (Pink, Orange and Red) • New settlements take a long time to plan and build, generating short to medium-term housing supply shortages (Red, but also potentially applicable to other options) • Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated (Red) • Exact route of the railway not yet known (Pink and Orange). 5.18 The Council therefore acknowledges that a similar pattern of constraints exists in relation to all three remaining options. The scope for the Review of the Local Plan 2030 should explicitly recognise this amongst reasons to select an appropriate strategy. 5.19 The Council also acknowledges that other locations would miss the benefits of growth if these strategic options were selected. However, in our view this is already an outcome of the existing Local Plan 2030 in terms of its reduced housing requirement and deferral of allocations to Neighbourhood Plans (as well as the current distribution of growth set out in Policy 4S). The Review of the Local Plan 2030 is also necessary to secure delivery of the Plan’s objectives in these other locations, including at Key Service Centres and Rural Service Centres. 5.20 Due to the combination of potential disadvantages it also follows that future solutions in terms of larger-scale development might look to resolve these in a manner that ensures these are overcome as part of options that maximise the benefits of these strategic options – for example New Settlement options that align with the delivery of East-West rail. The Council’s Orange – ‘East-West rail northern station growth option’ would most closely reflect these principles, albeit there remain uncertainties regarding timing and the approach to delivery of East-West Rail. 5.21 It is important to stress that given the potential timescales for East-West Rail any further assessment of such options is not incompatible with delivery of a range of other spatial options and achieving a sustainable distribution of growth in the rural area earlier in the plan period. We consider that the potential list of advantages associated with the Orange spatial option should include opportunities to complement and deliver net benefits aligned to the overall strategy. This is consistent with recommendations for a composite strategy incorporating appropriate assumptions for lead-in timescales and the requirements to support options such as New Settlements. 5.22 For example, there is no reason that future options for development based on the northern route alignment of East-West Rail cannot be achieved in-tandem with sustaining and enhancing the role of nearby settlements such as Milton Ernest and Sharnbrook. Site options associated with this approach, such as the potential Twinwoods New Settlement, could facilitate improvements to the A6 as well as enhancements to public transport and access to jobs and services. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 24 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.23 Appendix 4 of these representations provides commentary on the Council’s proposed methodology for site selection and updating is Housing and Economic Land Availability Assessment (HELAA). It is clear that the Council is seeking to align its conclusions following site assessment and testing of site options against the Plan’s sustainability objectives. This is to be welcomed, but only insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.24 As a result of the lengthy process for preparation of the Local Plan 2030, together with the deferral of site allocations, the Council’s previous evidence base generated disjointed conclusions on recommendations for site allocations. This lack of clarity in terms of findings against objectives for sustainable development means that preferred allocation options (such as those identified in the Council’s 2017 Consultation Paper) including all or part of our client’s sites at Sharnbrook, Oakley and Milton Ernest, are not necessarily reflected in the evidence base for emerging Neighbourhood Plans. 5.25 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA it does use arbitrary limits to growth (such as the current totals in Policy 4S of the Local Plan 2030) to exclude sites that are contrary to the development strategy. This is essential to ensure that the Council considers a flexible range of options. 5.26 In terms of the Site Selection Methodology this is an opportunity to formalise the conclusions for potential allocations including on a number of sites that Council has already assessed favourably. This is imperative in terms of policy development and securing allocations to meet needs over the plan period. Although the stages are comparable the following are important differences to earlier work: • The Council is currently considering a wider range of alternatives to the spatial strategy. This will allow the objective comparison of approaches to secure sustainable development. • The assessment of sustainability is based on clear indicators and criteria based on the Sustainability Objectives identified via the Council’s Scoping Report. This will inform a wider range of clear conclusions compared to the ‘Red Amber Green’ classification in the 2017 Options Assessment. • The list of secondary constraints is reduced compared to the 2017 Options Appraisal. This is welcomed and avoids duplicating the initial assessment of suitability, availability, and achievability through the HELAA. • At stage 3 (Community Infrastructure) the Council will give specific weight to proposals providing benefit to the wider community • As part of the overall conclusions the Council will note the “Contribution to strategy”. This is welcome, in the context of considering a more diverse range of site options and aligns with reasons that site options should not generally be excluded as part of the HELAA due to conflict with the options for the emerging spatial strategy. 5.27 The application of the Council’s proposed approach to strategy options, site assessment and site selection in relation to our client’s interests, is set out in the following sections. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 25 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission i) Spatial Option and Site Assessment Considerations for the Local Plan Review: Sharnbrook 5.28 Sharnbrook is an example of Key Service Centre that is demonstrably able to accommodate additional housing growth required in the period to 2030 and beyond. 5.29 The selection of the arbitrary figure of 500 units within Policy 4S of the current Local Plan is not justified in the context of the potential contribution towards the Plan’s objectives in this location. Sharnbrook comprises a highly sustainable settlement and the Council’s scoring in developing the settlement hierarchy places it in the top six centres under all iterations. 5.30 Furthermore, the provision of both a Primary and Secondary School demonstrates the settlement’s important role in providing services and facilities to the wider rural area. The ability to support higher levels of growth would therefore be justified based on a settlement-by-settlement approach to assessing capacity and having regard to available opportunities. 5.31 Our client’s interests comprise the combined sites at School Approach and Odell Road, Sharnbrook, and together would deliver key objectives for the settlement and wider area. The combined sites, which represent a key opportunity to achieve comprehensive development would deliver at least 500 dwellings. 5.32 The scale of development achievable coupled with and the comprehensive nature of the proposed scheme, enabling benefits to Primary and Secondary education in Sharnbrook, is unique to our client’s interest and fully justifies a somewhat higher overall level of growth than the requirements currently set out in Policy 4S of the adopted Local Plan 2030. 5.33 Critically, it is for the Local Plan to consider and make allocations which relate to strategic provision such as improved educational facilities, which in this case have catchment areas that extend beyond the Parish. These requirements are of greater importance given the cumulative levels of development being planned for, alongside the continued success of Sharnbrook Academy. 5.34 Details of the proposed scheme have been submitted to Sharnbrook Parish Council for consideration as part of the emerging Neighbourhood Plan for the area. A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.35 Notwithstanding the outcomes of this process it is essential that Bedford Borough Council objectively assesses all site options to achieve the longer-term requirements for development in Sharnbrook, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should the Neighbourhood Plan not proceed. In the event that the emerging Sharnbrook Neighbourhood Plan does not address the area’s strategic priorities for secondary education (including meeting the needs for Sharnbrook Academy) the potential for ‘supplementary’ allocations to deliver suitable options to secure these improvements should be assessed favourably as part of the Review. 5.36 We would therefore invite the Council’s Planning Policy Team to consider the previous site assessment findings for this location when assessing the submitted details. Both sites were considered favourably in the Council’s 2017 Consultation Paper, as part of preferred options for site allocation. 5.37 The Council’s 2018 HELAA records both sites as suitable, available, and achievable for development, and in its 2017 Assessment of Site Options the Council identified scope for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Sharnbrook’s role as a Key Service Centre and specific planning considerations regarding our client’s land including meeting the needs of Sharnbrook Academy, requirements for ecological mitigation and highways improvements. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 26 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 5.38 Potential constraints on development in this location have previously been assessed by the Council and did not affect conclusions regarding this location as a preferred allocation. Specifically, in relation to the proximity of the Felmersham Gravel Pits SSSI over 50% of the area for the proposed Masterplan would be devoted to non-built uses. In addition, Bedford Borough Council sought advice from Natural England (received January 2017) regarding the preferred allocation option. This confirmed that subject to an appropriate package of developer contributions the proposed development could be sustainably delivered. Potential impact pathways relating to hydrology and recreation would therefore be assessed and subject to mitigation in perpetuity as part of delivery of the site. 5.39 In relation to the Council’s site selection methodology and sustainability objectives the Council appears to be seeking to place greater weight on the potential adverse effects of sites that are located separately from the existing Settlement Policy Area boundary and relate poorly to settlement form. The Council’s Sustainability Appraisal Scoping Report also records that most of the land surrounding Sharnbrook is Grade 3 agricultural land, except for some Grade 2 ‘Very Good’ quality land immediately west of the A6. 5.40 The Council’s proposed objectives therefore appear to provide scope to demonstrate that our client’s site performs favourably against other alternatives in Sharnbrook given its proximity to existing services and facilities. This would further enhance the site’s ability to secure benefits for existing and future residents given its scope to deliver improvements to social and community infrastructure. ii) Spatial Option and Site Assessment Considerations for the Local Plan Review: Oakley 5.41 Oakley is a specific example of where the Council’s testing of the ‘Dispersed’ spatial option must also take account of the requirement to review the settlement hierarchy classification. The Council’s approach to the assessment of the settlement hierarchy in the Local Plan 2030 is flawed. It fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances provided by the Council. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available. 5.42 In terms of previously assessing the sustainability credentials of Oakley it is notable that the September 2018 Sustainability Appraisal findings (for the development of up to 250 units on Land on the eastern side of Station Road, Oakley – Site Ref 521) records potentially significant, positive impacts relating to minimising growth in car usage, reducing the need to travel and promoting the shift to more sustainable modes of transport. This means that at least 3 out of a list of local services (school, GP, general store, place of employment) are available within a 10-minute walking distance and also takes account of public transport accessibility to alternative services. 5.43 In addition, the Priory Medical Centre, located towards the western edge of Clapham, is easily accessible by walking and/or cycling (less than 0.8 miles). Local bus services also offer access by public transport. 5.44 The Council’s Settlement Hierarchy paper itself acknowledges that excluding specific provision of GP facilities in individual settlements may be more appropriate for determining the hierarchy. Oakley is one example of the rationale for this judgement given the proximity to Clapham and scores more highly in this iteration prepared by the Council. 5.45 Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 27 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission public transport. 5.46 The relative sustainability of Oakley reflects that it incorporates local shopping facilities, significant employment opportunities and has both a Primary and Secondary School. As such Oakley serves a wider catchment area. In this context it is a reasonable alternative to consider a higher level of growth than the 25-50 homes band identified in Policy 4S of the current Local Plan. 5.47 The key issue with the Council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the existing Settlement Hierarchy. As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth. 5.48 Incorporating these plan-making considerations as part of the Local Plan review is covered in the supporting text of the ‘made’ Oakley Neighbourhood Plan at page 12 paragraph 5.15. This includes considering proposals for the expansion of existing organisations (i.e. Lincroft Academy) where this may give rise to requirements for additional car parking. Furthermore, paragraph 4.31 of the Examiner’s Report specifically notes the configuration of the existing Lincroft Academy Playing Fields as part of potential future priorities for Oakley: “The playing fields are separated from the main part of the school buildings and Lincroft Academy wishes to reorganise its land parcels to enable the growth and efficient functioning of the school. In addition, Oakley Football Club has indicated that it is looking for flexibility in case a better site should come forward for the Club’s use. The designation of the site as LGS would limit the future options for the school in that reorganisation.” 5.49 The importance of these strategic priorities is emphasised by Lincroft Academy’s role in meeting increased requirements for school places, to support growth across a range of nearby settlements, including Clapham and Bromham. It is therefore entirely appropriate that the review considers levels of residential development at Oakley commensurate with addressing these local priorities for development, alongside sustaining a contribution towards housing needs in the period to 2030 and beyond. 5.50 A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.51 The proposed comprehensive option for development East of Station Road is supported by a number of sports organisations and Sport England with favourable conclusions previously set out by the Borough Council. Within this context it is important that the future opportunities for sustainable growth in Oakley are fully reflected by the Plan’s strategic policies following a review of the Local Plan 2030. 5.52 We consider that based on the Council’s proposed site selection methodology for the Review of the Local Plan 2030 the conclusions on this location as a preferred allocation option remain valid and would be reinforced. The Council’s proposed sustainability objectives should positively reflect the site’s proximity to existing services and facilities and its contribution towards delivery of new open space and community uses (objectives 7a and 14a). 5.53 There is a strong justification to review levels of growth in Oakley as part of the Review of the Local Plan 2030, including its potential to contribute towards the increased requirements for growth and delivery of other objectives in the period to 2030 and beyond. Recognising this ability to contribute towards the Plan’s objectives would address issues that extend beyond the immediate neighbourhood and relate to the overall level of planned growth. This proposal enables the expansion of education facilities and secures the provision of community use of the school’s enhanced sports facilities addressing acknowledged shortfalls BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 28 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission in community sport and recreation provision in the rural area.

6.1 The Council’s recognition of differences associated with the requirements for infrastructure arising from the different spatial options and implications for the delivery of growth is welcomed. In previously testing options that identified that increased levels of development in the rural area (principally Rural Key Service Centres and Rural Service Centres) that would be as sustainable the Council has acknowledged that opportunities exist to deliver these requirements as part of the ‘Dispersed’ growth strategy. 6.2 While the early delivery of infrastructure is supported as a key component for achieving sustainable growth, as set out in the Council’s consultation document, it is apparent that the current Local Plan 2030 is not founded on these principles. Specifically, this relates to the deferral of allocations to Neighbourhood Plans and the arbitrary totals for the apportionment of requirements adopted in Policy 4S. 6.3 The early delivery of local infrastructure requirements should be supported. This should be clearly set out through the policies and allocations of the Local Plan Review. Meeting the Plan’s additional requirement for housing growth should therefore be aligned with specific additional allocations that would secure local opportunities for sustainable development, in the event that these have not been secured via Neighbourhood Plans given the constraints imposed through the Local Plan 2030. As illustrated below, additional allocations should be specifically supported on the basis of their deliverability – for example land such as our client’s interests Oakley and Sharnbrook. 6.4 In the case of Oakley, for example, the classification of the settlement as a Rural Service Centre also contributes to the strategy failing to address the future requirements of Lincroft Academy. Furthermore, the approach towards determining levels of growth in the current Local Plan does not identify specific constraints to further levels of growth in settlements including Oakley or Sharnbrook. 6.5 Given this context it is clear that as part of the Dispersed spatial option the Council should not impose arbitrary limits to delivering further contributions towards the increased housing requirement together with the other needs of development where this can be achieved in a co-ordinated and sustainable manner. This is consistent with the advantages for this option identified by the Council, in terms of ensuring a greater number of communities observing the benefits of growth, in a manner not currently secured due to the limits of the Local Plan 2030.

7.1 We consider that the Review of the Local Plan 2030 should be positively prepared in terms of assessing a range of opportunities to support economic development that are compatible with the different spatial options being assessed and capable of addressing requirements for future growth. 7.2 To ensure sufficient employment land is available to support housing growth, we would emphasise that when evaluating potential options for allocation and existing land use designations, consideration should be given to potential sites that could provide optimize opportunities for economic development in rural areas as well as potential infrastructure that would improve the delivery of employment sites. This would be in accord with national policy to support a prosperous rural economy (NPPF2019 paragraph 83) and consistent with opportunities for sustainable development as part of a ‘Dispersed’ spatial strategy. 7.3 As part of sustaining and enhancing the role of Key Service Centres and Rural Service Centres as well as meeting needs across the wider rural area it is important that existing and future opportunities for economic development are supported by the Plan’s policies. Increasing opportunities for economic development would further provide opportunities to reduce the need for travel and facilitate job creation alongside housing growth. 7.4 We would invite the Council’s Planning Policy Team to consider the previous site assessment findings for land within our client’s control when considering locations where job creation may be supported. In the case of our client’s Land adjacent to Highfield Road, Oakley and Land off Rushen Road, Milton Ernest both sites were considered favourably in the Council’s assessment of sites. The Council’s 2018 SHELAA records both sites as having the potential for employment as its primary use and would be suitable, available, and achievable for development. 7.5 These conclusions remain entirely valid in the context of the role of Oakley and Milton Ernest and specific planning considerations regarding our client’s land that provide opportunities to accommodate the Borough’s growth 7.6 In relation to our client’s land adjacent to Highfield Road, Oakley, the site is considered suitable for a high calibre employment site (across the B1/B2/B8 Use Classes at a scale appropriate to the local area). The site offers an opportunity for the consolidation of the existing employment development on Highfield Road, which was purpose built and offers arrange of ‘mid-size’ units for a range of ‘B’ type uses. Policy BE1 of the Oakley Neighbourhood Plan provides support for a range of B1/B2/B8 uses within the existing Highfield Park. 7.7 The site is contained by existing development comprising the Midland Main Railway Line, existing housing, employment uses and the A6 Clapham Bypass. This contained setting would result in development appearing as a logical extension to Oakley and can also benefit from appropriate landscaping to mitigate impacts upon rural character and separation with Clapham to the south and east. The site has the capacity to accommodate approximately 3ha of employment development and offers an opportunity for innovative design and job creation. 7.8 Our client’s Land at Rushden Road, Milton Ernest comprises a part-previously developed site that is well-related to the existing settlement area and with part of the site area in existing commercial use. Allocation of this area for employment uses together with an opportunity to increase opportunities for additional floorspace and job creation and would complement the existing role of the site. It is therefore requested that based on the above examples the Review of the Local Plan 2030 provides an enhanced range of policies and allocations to support economic development in the rural area. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 31 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 8.0 QUESTION 7 – ROLE OF THE OXFORD-CAMBRIDGE ARC 8.1 The response to this question should be read alongside or overall observations regarding the spatial options identified by the Council under Question 4. The role of the Oxford-Cambridge Arc is supported in terms of identifying and delivering the priorities for plan-making. However, the Arc itself is not specifically referred to in the text of Policy 1 and does not appear to be identified as part of the assessment criteria for the emerging Plan’s Sustainability Objectives. This reflects the continued uncertainties regarding delivery of growth across the wider sub-region and features such as the Expressway. 8.2 In this respect there has been only limited progress compared to the Council’s conclusions when preparing the Local Plan 2030. This acknowledged the uncertainty of planning for the wider corridor and while it was anticipated that future decisions would align with the timescales for this Review this cannot be guaranteed. Testing of options to meet full development needs should not be further constrained by these outstanding uncertainties. 8.3 It is appropriate that the strategy for the Review of the Local Plan 2030 capitalises on those existing commitments for infrastructure improvements (including the A421 corridor) as well as meeting the needs of individual settlements and enhancing the role of Bedford. This would ensure that the Plans priorities are delivered rather than deferred (as is the case in the Local Plan 2030) while remaining consistent with longer-term objectives for the corridor.

8.1 The response to this question should be read alongside or overall observations regarding the spatial options identified by the Council under Question 4. The role of the Oxford-Cambridge Arc is supported in terms of identifying and delivering the priorities for plan-making. However, the Arc itself is not specifically referred to in the text of Policy 1 and does not appear to be identified as part of the assessment criteria for the emerging Plan’s Sustainability Objectives. This reflects the continued uncertainties regarding delivery of growth across the wider sub-region and features such as the Expressway. 8.2 In this respect there has been only limited progress compared to the Council’s conclusions when preparing the Local Plan 2030. This acknowledged the uncertainty of planning for the wider corridor and while it was anticipated that future decisions would align with the timescales for this Review this cannot be guaranteed. Testing of options to meet full development needs should not be further constrained by these outstanding uncertainties. 8.3 It is appropriate that the strategy for the Review of the Local Plan 2030 capitalises on those existing commitments for infrastructure improvements (including the A421 corridor) as well as meeting the needs of individual settlements and enhancing the role of Bedford. This would ensure that the Plans priorities are delivered rather than deferred (as is the case in the Local Plan 2030) while remaining consistent with longer-term objectives for the corridor.

9.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.

I agree

10.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.