Issues and Options

No

The scope of the Local Plan Review should be informed by the Government’s proposed reforms to the planning system. Whilst the detail of those reforms is not yet clear, the publication of the Planning White Paper provides a direction of travel that should inform how the local plan review progresses in parallel with the Government’s intentions. For instance, any development management policies should clearly be specific to particular areas or proposed allocations.

The vision states ‘Rural communities will embrace sensitive development through neighbourhood plans that provide and support much needed housing and employment…’ and this is consistent with the approach within the adopted Local Plan for certain Key service and Rural service centres. The delegation of responsibility for determining the location of growth to designated neighbourhood areas is consistent with paragraph 65 of the NPPF, however in the circumstances of this Local Plan Review it may not be appropriate for all areas. The increase in the housing requirement and the need to demonstrate a supply of specific deliverable sites will require the need for sites which can deliver quickly. However, the requirement for such sites to be allocated within a Neighbourhood Plan introduces delay and uncertainty through a process which the Council cannot control. This could ultimately undermine the soundness of the Plan. The Local Plan Review should therefore be making allocations in neighbourhood areas where it is necessary to ensure it can demonstrate housing delivery, and not delegate responsibility to neighbourhood plans given the delay and uncertainty that arises. Further, where responsibility is delegated, the Local Plan Review should also set out what approach it will take to plan making or planning applications in areas where a local community is unwilling to prepare, progress, or update a Neighbourhood Plan in a timely manner in accordance with the Council’s trajectory. Consideration should also be given to the Vision containing specific reference to boosting the supply of homes in the Borough, particularly given the Government’s objectives both nationally and in relation to the Arc.

I do not agree with this plan period

It is noted that other authorities within the Arc are considering preparing plans over a longer period to 2050 (including West Northamptonshire and Milton Keynes). Having consistency across the Arc would be beneficial in aligning strategies for growth and infrastructure across local authority boundaries. Further, this would align with the announcement in the Government’s Budget of March 2020 to prepare a long-term spatial framework in the Oxford to Cambridge Arc up to 2050. This Local Plan Review could clearly have a role in informing the content of the Government’s spatial framework, particularly so if it aligns with its timeframe.

Nothing chosen

It is important for the Local Plan Review to recognise that housing and employment need are primarily generated from within existing communities within the Borough. Therefore in order to best meet those needs, and enable those communities to thrive, growth will need to be dispersed to all settlements of a certain size. The level of growth apportioned to each settlement needs to be assessed in light of the overall housing requirement, reflect the settlement hierarchy, and be informed by the housing land availability assessment. Dispersed growth is therefore the supported option as it is the most sustainable way to meet future need. In terms of the disadvantages of the dispersed growth option noted in the consultation paper, reference is made to it may be requiring growth in communities with no or very few facilities. That disadvantage could be avoided at the stage at which growth is distributed. Reference is made to a lack of a critical mass making providing new strategic infrastructure more difficult, however the way in which infrastructure is funded is clearly evolving in light of the Government’s intentions in its White Paper. Reference is also made to it being unlikely to facilitate employment growth due to dispersed nature, however a broader range of sites and sizes would provide more opportunities for housebuilders of all sizes. In terms of the other options presented, urban and new settlement based growth would not necessarily locate housing and employment in locations accessible to those existing communities where the need is derived. This is a particular issue in terms of affordable housing, where those residents in housing need are often reluctant to take properties in locations remote from family, social networks, or workplaces, such as those identified on the edge of the Borough around Rushden or St. Neots. Further, focussing significant amounts of investment and public resources into creating new settlements, diverts attention away from addressing the needs of existing communities in terms of improved infrastructure and facilities. As noted in the consultation paper, given the length of time required in bringing new settlements forward (8.4 years from validation to first completions based on the Start to Finish Second Edition research), they can also only realistically play a small part in terms of housing and job delivery in the short to medium term. The options linked with sustainable transport corridors, whether that is rail stations or bus routes along the A421, clearly have the potential to encourage greater use of sustainable modes of travel and are therefore consistent with national policy in that respect. As a factor, therefore, this might influence the proposed distribution of growth between settlements, but not to the extent that settlements outside of these corridors do not expand. Many of the settlements outside of these corridors still have good sustainable transport links, particularly those around the urban edge of Bedford. New development in such locations will support the continued operation of transport connections and provides the opportunity to enhance such connections. With specific reference to Rainier Developments land interests at Bromham, which has been presented to the Council through the ‘call for sites’ process, support is given for a strategy which includes housing growth at Bromham. Bromham is a key service centre in the adopted Local Plan and very close to the urban edge of Bedford. Indeed, in the Settlement Hierarchy evidence submitted in support of the adopted Local Plan, it is identified as the highest ranking and largest of the settlements within the key service centres category. Beyond Bedford/Kempston urban area, it is arguably one of the most sustainable locations to accommodate growth within the Borough and therefore must play a role in meeting future needs identified through the Plan Review. Bromham is identified to deliver 500 homes within the plan period to 2030, and it would be appropriate to take at least a similar quantum of growth again over the longer plan period to 2040.

I agree

In preparing the Local Plan Review, the Council will need to be mindful of the Government’s intentions in reforming the planning system to simplify Local Plans and ensuring that the Framework provides the clear and robust basis for development management decisions generally in respect of climate change.

No

Reference is made within the consultation paper to the housing requirement, and views being sought on a housing figure in the range of 800 – 1305 dwellings per annum. The figure of 800 dwellings per annum is not based on the current or proposed standard methodology, and therefore should not be taken forward as a basis for calculating the housing requirement. The proposed standard methodology has a figure of 1,153 dwellings per annum, and it would be prudent for the Council going forward to test levels of growth between 1,153 and 1,305 dwellings per annum. The Council will need to continuously engage with other strategic policy making authorities through the Local Plan Review to ensure any needs that cannot be met within neighbouring areas are considered. The Council will also need to ensure that its assumptions regarding the anticipated rate of delivery of existing commitments are realistic, and that an appropriate buffer is included to ensure delivery in accordance with the Framework. Further analysis and evidence will therefore be required to support the figures referenced in page 16 of the consultation paper.