Issues and Options

1.0 INTRODUCTION 1.1 On behalf of client Philip C Bath Ltd, we are pleased to submit details of the above sites for consideration as part of the Review of the Bedford Local Plan 2030 – Issues and Options Consultation Document. 1.2 Details of our client’s specific interest have been submitted as part of the ‘Call for Sites’ exercise undertaken alongside this consultation. Details of the relevant submissions are summarised below: • Land at Ford Lane, Roxton o High Barns Farm, Roxton 1.3 In commencing an immediate Review in accordance with Policy 1 of the adopted Plan the Council is, as required, seeking to ensure that future needs for growth are provided for in-line with government policy i.e. local housing need calculated using the standard method. 1.4 This will entail meeting a significant (up to c.35%) increase in the minimum annual requirement for development for at least the period 2020-2040 upon adoption of the Review, expected in 2023. The Review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs. 1.5 The scope for the Review has been enhanced as a consequence of the foreshortened plan period of the current Plan, and its strategy of apportioning specific (albeit minimum) values for the distribution of housing across the settlement hierarchy and the deferral of site allocations to Neighbourhood Plans. Equally, the challenges of housing delivery must also reflect realistic timescales to ‘unlock’ developable sites in the Urban Area, as well as ensuring necessary supporting infrastructure in other locations. 1.6 The Borough Council has acknowledged this through consideration of a diverse range of spatial options to inform the Local Plan Review. As stipulated by national policy this is an opportunity to ensure that plans are positively prepared in terms of seeking opportunities for sustainable development and proactively pursue appropriate growth. 1.7 These representations seek to reinforce and refine the Council’s proposed objectives for development in the Borough, and with specific reference to our client’s interests demonstrate how these can be sustainably delivered in Roxton. As a Rural Service Centre, whose status as such is not disputed by the Council in the context of undertaking the Local Plan Review, Roxton is accepted as a sustainable location for growth. 1.8 The Council has previously assessed that options for the delivery of increased requirements for growth in the rural area would be just as sustainable as those selected (i.e. New Settlements) and then abandoned due to feasibility constraints in the course of preparation of the Local Plan 2030. The Council is assessing various spatial options where further growth at Roxton would make a sustainable contribution to the overall spatial strategy (e.g. as part of a ‘Dispersed’ strategy or a combination of options). 1.9 For the purpose of these representations it is, however, critical to note that the spatial strategy of the adopted Local Plan 2030 is silent on the relationship between planned and future improvements of the A421 corridor and opportunities to deliver the Plan’s strategic priorities. In recognition of this, a spatial option for A421-based growth is specifically identified in the Council’s consultation documents and is associated with the most substantial balance of advantages in favour of sustainable development. 1.10 We consider that in terms of assessing options for the spatial strategy, and in terms of considering reasonable alternatives for the assessment of sites and site selection, the Council must take a positive approach to each of the following elements and avoiding placing arbitrary constraints on appropriate, sustainable levels of growth. These representations explain why the Council must ensure that the role of Roxton within the Council’s settlement hierarchy and its contribution toward the proposed distribution of development requirements is assessed in the context of opportunities to secure A421-based growth. 1.11 As a result, it is inevitable that Roxton as a Rural Service Centre has the capacity for growth, given it is favourably located in the A421 Corridor. Unlike other settlements in the Borough, where a Neighbourhood Development Plan is required to identify sites (under Policy 4S), Roxton has been allocated sites in the Local Plan 2030 (under Policy 27 – Land north of School Lane). It is clear, however, from Policy 4S that the approach towards this specific allocation and apportionment of growth in Roxton has been grouped together within the arbitrary range for development of 25-50 units in Rural Service Centres considered as part of the Local Plan 2030. This reflects that foreshortened plan period and reduced housing requirement pursued under the NPPF2012 transitional arrangements, rather than illustrating that the approach has had regard to the full capacity for growth or opportunities to contribute towards longer-term objectives for each individual Rural Service Centre in the settlement hierarchy. Notwithstanding that this provides a clear context for additional allocations in Roxton to be provided directly as part of the Local Plan Review process this should properly reflect a standalone assessment of the levels of growth that might be supported towards planned requirements. 1.12 It is essential that the delivery of an appropriate strategy, as part of the Review of the Local Plan 2030, is supported through both its strategic policies and allocations. This is necessary to ensure that current priorities and future opportunities to secure sustainable development are not again deferred to future rounds of plan-making. For this reason, we believe that the following elements should become a clear focus for the scope of the review and through these representations demonstrate how our client’s interests would support the achievement of sustainable development: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). This should particularly focus on existing and planned infrastructure improvements along the A421 Corridor, to capitalise on this strategic priority and opportunity it provides to meet future needs. • 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 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, including avoiding over optimism regarding forecast delivery towards the Plan’s requirements from sites in the Town Centre within the period to 2030 and beyond.

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 Plan’s 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. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 8 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 However, current planned improvements (such as those related to the A421 corridor) are not sufficiently reflected in the Local Plan 2030. This reveals the existence of strategic spatial options that the Council might support in the immediate term. 2.9 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 is below levels previously tested and found to be just as sustainable as other options. Roxton is a particular example where the capacity for growth is substantially greater than the apportionment of requirements identified by Policy 4S and Policy 27 of the current Plan. This is before considering the settlement’s location within the A421 corridor. This, together with deferral of allocations to Neighbourhood Plans, constrains the Council’s ability to effectively meet its priorities for development through the current strategy in the Local Plan 2030. 2.10 Thirdly, and related to this, the delivery of substantially increased requirements for growth necessitates an approach that more fully reflects the requirements and opportunities to support 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 as part of sustainable spatial options. Roxton is uniquely placed in this context given its credentials as a Rural Service Centre within the A421 corridor. 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 9 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. Greater weight should be given to those site options that offer clear benefits for delivery. For example, our client’s interest at Land at Ford Lane, comprises 7.5 ha of land withing single ownership that can support comprehensive residential development of 100 units. 2.13 The following sub-sections of this response consider the requirements for plan-making as part of the Local Plan review in the context of national policy and other material considerations. (a) National Policy and Guidance – Implications for the Review of the Local Plan 2030 (i) Plan-Making 2.14 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. 2.15 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. 2.16 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 10 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. 2.17 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. 2.18 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). 2.19 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. 2.20 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. 2.21 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 11 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 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. 2.22 In relation to housing in the rural area 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. 2.23 Paragraph 65 of the NPPF2019 stipulates 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). It is therefore not a sound basis for plan-making to suggest that the housing requirement figures in Policy 4S of the Local Plan 2030 will not be reviewed as part of this process. Particularly for settlements such as Roxton the updated requirement must positively reflect the ability to contribute towards the A421-based spatial option. 2.24 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 12 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. 2.25 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). This should particularly focus on existing and planned infrastructure improvements along the A421 Corridor, to capitalise on this strategic priority and opportunity it provides to meet future needs. • Ensure that opportunities to sustain and enhance the role of settlements within the settlement hierarchy (e.g. Roxton as a Rural Service Centre) fully reflects their capacity for growth and positive relationship with wider spatial options e.g. A421-based growth. • 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 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, including avoiding over optimism regarding forecast delivery towards the Plan’s requirements from sites in the Town Centre within the period to 2030 and beyond. 2.26 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. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 13 (b) Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 2.27 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. 2.28 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. 2.29 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). 2.30 It should also be noted that in terms of taking forward options previously tested the current Local Plan takes no account of planned improvements along the A421 corridor. The potential for higher levels of growth in the rural area takes no account of the distribution amongst individual settlements. This is particularly important for the settlement of Roxton, where the potential effects of higher levels of growth would also accord with the positive outcomes of delivering the A421-based spatial option. Revisiting the scope for appropriate higher levels of growth in the rural area should specifically reflect this spatial context for Roxton. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 14 (c) Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 2.31 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). 2.32 The Council’s current calculation of a Five Year Supply of deliverable sites demonstrates 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). 2.33 Table 1 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 1: 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 1305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1153 28 -2,277 -9,883 -5,765 -12,132 -17,897 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 15 2.34 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 growth 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. 2.35 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 the undermine the Council’s current claimed 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. 2.36 Table 2 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: BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 16 Table 2: 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 2.37 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. (d) Impact of Government Consultation on Proposed Planning Reforms 2.38 In terms of considering the potential implications of the government’s ‘Planning for the Future’ White Paper, in the context of the scope for the Local Plan Review, it should be noted that the contents of the White Paper comprise consultation proposals only. Presently they 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. 2.39 It should be noted, however, that where page 16 of the Council’s consultation document BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 17 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. 2.40 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. Specifically, however, the current Vision in the Local Plan 2030 fails to reflect those spatial options and planned improvements that can make a clear contribution to the Plan’s strategic priorities, such as A421-based growth at Roxton. The settlement is a clear example of where the levels of growth that can be sustainably planned for exceed the apportionment of requirements identified in the current Plan. 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 This statement, particularly in the context of Roxton, fails to note that the current spatial strategy is silent on the strategic priorities and opportunities for A421-based growth. It also fails to take account of the fact that the apportionment of growth was determined by arbitrary assumptions on capacity against a constrained plan period and housing requirement reflecting the NPPF2012’s transitional arrangements. Delays to the delivery of growth are further compounded by the deferral of site allocations to Neighbourhood Plans. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 19 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. A substantially greater contribution towards annual requirements for development at Roxton 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. This would seek to fully sustain and enhance its role as a Rural Service Centre while helping to deliver the Council’s strategic priorities as a result of the advantages associated with A421-based growth. 3.7 We have identified three main elements of the Council’s proposed Vision where amendments 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.” “Delivery of the Borough’s infrastructure priorities throughout the plan period has maximised opportunities associated with planned improvements, including enabling a focus for sustainable growth along the A421 corridor. The early allocation of sites to meet additional requirements for growth has been supported, with a focus on opportunities that secure delivery of the Plan’s objectives for sustainable development, complemented A421-based growth. The development of East-West Rail through Bedford will be complete. Bedford will benefit from a new town centre transport interchange including links to Oxford and Cambridge, increasing connectivity, investment and growth. Local development will be well served by transport links and speedy internet access integrated into the planning process and completed before residents move in.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. 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 2758 completions for the period 2020/21 to 2022/23 i.e. an under-delivery (i.e. 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. This does not preclude the potential for longer-term options to be considered as potentially contributing towards development needs outside of the minimum 15-year plan period, but the Borough Council continues to accept substantial uncertainties regarding options related to New Settlements or East-West Rail. 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 21 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.

Nothing chosen

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 comprising New Settlements and large-scale urban extensions. 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 (saved 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 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. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 23 5.7 For the purpose of these representations it is, however, critical to note that the spatial strategy of the adopted Local Plan 2030 is silent on the relationship between planned and future improvements of the A421 corridor and opportunities to deliver the Plan’s strategic priorities. In recognition of this, a spatial option for A421-based growth is specifically identified in the Council’s consultation documents and is associated with the most substantial balance of advantages in favour of sustainable development. 5.8 For Roxton, the settlement to which these representations relate, it is important to note that within the context of the Council’s settlement hierarchy its designation as a Rural Service Centre is not in dispute. Paragraph 64of the Local Plan Inspector’s Report notes that the settlement scores well in all iterations of testing classifications within the hierarchy. 5.9 It is therefore acknowledged that the Council is assessing various spatial options where further growth at Roxton would make a sustainable contribution to the overall spatial strategy (e.g. as part of a ‘Dispersed’ strategy or a combination of options). However, it is important to note that Roxton’s current classification within the settlement hierarchy takes no account of its positive relationship with planned and future improvements within the A421 corridor nor its wider links with the Oxford-Cambridge Arc. 5.10 These arguments were in effect accepted due to the requirement for an immediate review under Policy 1. 5.11 For this reason, we recommend that the Review of the Local Plan 2030 is based around a strategy that fully reflects and capitalises upon opportunities for sustainable development associated with the Yellow – A421 based growth spatial option. 5.12 Further initial observations on the A421-based growth option 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. (e) Summary of Conclusions on Preferred Spatial Distribution Option 5.13 Yellow – A421 based growth – Selection of this option for significant further testing is supported. This option would better recognise the strategic priorities and opportunities for development in this location relative to the existing development plan and this is to be encouraged and is consistent with national policy and guidance. The Council’s own BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 24 consultation document acknowledges that this Option has the longest list of advantages and capitalises 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 principally includes the Key Rural Service Centre of Great Barford and the Rural Service Centre at Roxton. This option is this capable of achieving moderate to strategic-scale growth based on planned and anticipated improvement in infrastructure. Opportunities to maximise net gains through development in Roxton would be achieved through reviewing the requirements identified in existing Policy 4S. 5.15 It is evident that the minimum requirement identified in the Local Plan 2030 is not sufficient to capitalise on all plan-making objectives in Roxton, which are further impacted by housing not being allocated in Neighbourhood Plans, but instead through the Local Plan. This means that the scope for supplementary allocations and delivery of contributions towards the Plan’s objectives must be led by the apportionment of growth through the strategy of the Local Plan Review. Allocation of our client’s full opportunity for development at Land at Ford Lane (100 units) would make a significant contribution towards an appropriate overall strategy and contribute to addressing the shortfall in meeting requirements set out in accordance with government policy. 5.16 We consider that development opportunities within the corridor east of Bedford are preferable when considering the assessment of alternatives. Specifically, this reflects existing sustainable transport options including the route of the X5 linking Bedford and Cambridge. This area of the corridor also generates less potential impact as a result of cumulative levels of development south and west of Bedford (noting the proposed allocation of Marston Vale villages in the emerging Central Bedfordshire Local Plan and extant commitments at Wixams). (f) Summary of Conclusions for Alternative Spatial Distribution Options 5.17 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 25 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 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. 5.18 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, meaning 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). 5.19 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. 5.20 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. (g) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.21 This commentary relates to the Council’s proposed methodology for site selection and the approach to 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 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 26 insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.22 Our main concern relates to the following suggestion to exclude “Sites that are not in accordance with the development strategy of the emerging local plan.” The Council’s reasons acknowledge that the development strategy will be subject to substantial further assessment as part of testing alternatives. We therefore consider this criteria as inappropriate for the Stage 1 assessment at the current point in plan-making and that very few candidate sites could be ruled out on this basis. This is on account of the diverse range of spatial options that the Council is required to consider. 5.23 Planning Practice Guidance governing the assessment of land availability is consistent with our suggestions. This stipulates that plan-making authorities should consider how relevant constraints can be overcome and where future policy changes may affect choices on the scale or location of development (PPG ID: 3-018-20190722). It is also the case the Bedford Borough is affected by very few of the constraints identified at footnote 6 to paragraph 11 of the NPPF2019 that may override the assessment of the suitability of land to meet identified needs (ID: 3-002-20190722). 5.24 Where sites put forward in principle accord with any of the spatial options currently being considered (e.g. A421-based growth at Roxton) the Methodology should note that this will be recorded and that such sites will not be excluded on grounds of potential conflict with the strategy. 5.25 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA the Council does not 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 There are four key elements of the Council’s proposed more detailed methodology for site selection: • An Assessment against Sustainability Objectives • Review of Additional Technical and Policy Constraints • Other Considerations including Infrastructure and Contribution to Housing Delivery • Conclusions including contribution to Local Plan strategy and objectives BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 27 5.27 These four stages are essentially the same as the Council’s 2017 Options Assessment, but the Review of the Local Plan 2030 offers an opportunity to formalise the conclusions for site selection. 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. 5.28 The Council also proposes to include consideration of the contribution options are likely to make towards supporting and diversifying Housing Land Supply as part of the site selection process. “Contribution to improving housing supply through broadening the range of sites that are available. The Government recognises that small and medium sized sites can make an important contribution to meeting housing requirements.” 5.29 This is welcomed. However, in rural areas this will also be as part of a boost to supply from options that exceed the 1ha threshold in national policy. 5.30 Our client’s specific interests within Roxton comprise an opportunity for the development of 100 homes at land at Ford Lane. This would contribute towards the strategic priorities and opportunity for growth within the A421 corridor, including meeting a greater proportion of the Borough’s housing requirements in this location. In terms of national policy for rural housing and the role of development in one location helping to support the needs and services of other centres the relationship between Roxton and Great Barford within the A421 corridor should also be weighed favourably in terms of the site selection process. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 28 5.31 Given the underlying issues with the strategy in the Local Plan 2030 in terms of securing options to deliver future requirements for growth it is essential that the objectives for development in the A421 corridor are set out through the policies and allocations in the Plan. The role of Roxton as a Rural Service Centre is key to delivering this spatial option. 5.32 We submit that the most logical and effective basis upon which to plan for growth would be to undertake a thorough analysis of the ability of each settlement to accommodate growth, taking into account factors such as the level of services and capacity of local infrastructure, but also the availability of suitable and available land for development. This would result in a more deliverable and effective approach that would avoid placing arbitrary targets on certain settlements which could arguably accommodate a greater level of growth.

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. The Council is already aware that options exist to deliver identified requirements as part of equally sustainable options to distribute growth within the rural area, particularly across Key Service Centres and Rural Service Centres. This is especially relevant for Roxton, albeit the current Local Plan is silent on the settlement’s ability to support A421-based growth. 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 at Roxton. 6.4 The Council has recognised opportunities for A421-based growth to reflect planned infrastructure improvements. This further reinforces the opportunity meet the requirements for growth in a sustainable manner at the Rural Service Centre of Roxton. Given the context outlined above it is clear that as part of this spatial option the delivery of contributions towards the increased housing requirement together with the other needs of development can be achieved in a co-ordinated and sustainable manner. 6.5 In terms of the Council’s advantages identified as part of the A421 option, including delivery of phased growth and recognising the role of existing and future planned improvements, it is essential that these opportunities are specifically supported via the policies and allocations of the Plan.

7.1 In relation to specific locations or requirements for employment growth, we reserve our position to consider specific policy proposals as part of subsequent stages of consultation. 7.2 In relation to the Plan’s strategic priorities and links with the wider sub-region it is, however, noted that the Council’s spatial options recognise the benefits of A421-based growth in terms of minimising journey times and facilitating sustainable access to a range of labour markets and opportunities for economic development, in particular our client’s site at High Barns Farm, Roxton.

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.

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

12.1 On behalf our client’s we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. 12.3 Specifically, in relation to the Council’s spatial options, greater weight should be given to site options providing for A421-based growth. As acknowledged in the Council’s list of advantages for this strategic option the A421 corridor provides sustainable links to a wide range of employment opportunities. In terms of modal shift, the corridor already benefits from intercity public transport links connecting major settlements within the Oxford-Cambridge Arc with other sustainable settlements such as Roxton.