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 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 NPPF 2012 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. It is, however, accepted that there are some planned improvements such as those centred around the A421 corridor that may enable some greater proportion of needs to be met in the early part of the plan period through a combination of option. 2.8 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres in the Local Plan 2030 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. 2.9 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local 8 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. 2.10 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 ‘top-up’ 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. 2.11 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 ‘top up’ allocations should be provided for as allocations rather than being further deferred to the preparation or review of Neighbourhood Plans. 9 3.0 NATIONAL POLICY AND GUIDANCE – IMPLICATIONS FOR THE REVIEW OF THE LOCAL PLAN 2030 Plan-Making 3.1 It is helpful to provide a brief overview of policies in the NPPF 2019, governing plan-making and central to assessing the soundness of proposals to be prepared as part of the Review of the Local Plan. 3.2 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. 3.3 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. 3.4 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. 3.5 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) 3.6 Paragraphs 31 to 33 of the NPPF 2019 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. 3.7 In relation to identifying land for housing in the context of options identified in the Borough’s consultation proposals paragraph 72 of the NPPF 2019 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. 10 3.8 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: 3.9 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 3.10 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 3.11 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”. 3.12 The requirements of NPPF 2019 Paragraph 72 should be explicitly acknowledged to frame the Council’s assessment of strategic growth options. Rural Housing and Implications for the Existing Spatial Strategy 3.13 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. 3.14 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 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. 3.15 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 NPPF 2019 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. 3.16 Planning Practice Guidance notes that plan-making authorities should consider the broader 11 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) 3.17 The importance of these elements of national policy are reinforced by Paragraph 65 of the NPPF 2019 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). 3.18 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. 3.19 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. Conclusions to Inform the Scope of the Review of the Local Plan 3.20 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 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 12 constraints to this component of the overall strategy in terms of timeframes and levels of growth. • Support the provision of accommodation for older people on suitable sites where this an identified need for this type of accommodation. 3.21 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. Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 3.22 In terms of the testing of options for the distribution of growth it is important to stress that during the preparation of the Local Plan the Council only excluded options for higher levels of growth in rural villages purely on the grounds that the level of development was beyond that required by the draft Plan. 3.23 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: 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 1 9 0 0 0 2630 high growth 5100 low growth 225 795 5 SA September 2018 1 3 0 100 0 high growth 2895 high growth 4000 low growth 260 725 5 3.24 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. 3.25 It is also a logical approach 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. 3.26 Delivery of growth in the rural area remains of key importance to avoiding negative impacts 13 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). 3.27 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 rural areas is at 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. 3.28 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 Turvey. 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 NPPF 2019 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. Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 3.29 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). 3.30 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). 3.31 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. 14 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 3.32 The figure of at least 3,341 units broadly determines the scope for ‘top up’ 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 ‘top up’ allocations and does not impose arbitrary caps to growth in individual settlements as well as reflecting those centres where capacity is greatest. The ability for deliverable ‘top up’ allocations suitable to meet increased requirements in the period to 2030 should be considered favourable in the context of assessing site options and site selection. 3.33 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 the conclusions undermine the Council’s current claimed supply of deliverable sites: 3.34 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) 3.35 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) 3.36 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 3.37 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: 15 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 3.38 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. Impact of Government Consultation on Proposed Planning Reforms 3.39 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. 3.40 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. 3.41 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 16 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.

4.1 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. 4.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres than 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. 4.3 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. 4.4 The vision should also include reference to supporting proposals that provide suitable accommodation for older people. There is a clear rising need for specialist accommodation for older people in the Borough, and this should be a key part of the vision and the proposed strategy of the Local Plan. 4.5 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.” 4.6 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: i. 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 (including the proposed allocation of a New Settlement) ii. 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 iii. 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 4.7 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’ 18 strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at Turve/Turvey Station than the levels currently indicated by Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 4.8 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). 4.9 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.” “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 do not agree with this plan period

5.1 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. 5.2 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) 5.3 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. 5.4 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 or shortfall of 1,157 units to be addressed upon adoption. 5.5 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. 5.6 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 infrastructures 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.

Nothing chosen

6.1 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. 6.2 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 NPPF 2012’s transitional arrangements for housing need. 6.3 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. 6.4 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. 6.5 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. 6.6 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. 6.7 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. 6.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 6.9 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 21 a whole. Summary of Conclusions on Preferred Spatial Distribution Options 6.10 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. 6.11 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 underprovision 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. 6.12 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 6.13 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. 6.14 The improvements complement longer-term strategic objectives for planning across the subregion 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. 6.15 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 larger villages based on their alignment with the Plan’s wider priorities. Summary of Conclusions for Alternative Spatial Distribution Options 6.16 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 22 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 NPPF 2019 and in-particular part (d) requiring consideration of likely delivery in the plan period. 6.17 Amongst the disadvantages associated with the remaining 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). 6.18 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. 6.19 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. 6.20 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 extreme uncertainties regarding timing and the approach to delivery of East-West Rail. 6.21 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. Spatial Option and Site Assessment Considerations for the Local Plan Review: Turvey/Turvey Station 6.22 Our client’s interest comprises land adjacent to the former grain store at Station Road, Turvey. Planning permission has been granted under reference 19/01018/M73 for 128 Class C2 units (Phase 1) and 19/01956/MAF for 62 Class C2 units (Phase 2) on land adjoining this site to the east for a Class C2 Care Village on behalf of Inspired Villages. Development on this additional parcel of land would be a modest addition as a phase 3 for approximately 20 23 Class C2 units and would form part of the previously approved care village to provide additional accommodation, parking, and landscaping etc. The proposal would provide much needed suitable accommodation for older people as well as enhanced landscaping to the boundaries and also within the site. The proposed development would also create jobs and improve the existing connectivity with existing public footpaths. 6.23 Our client’s site would contribute towards meeting the rising need for elderly accommodation and furthermore, the Council acknowledge that this is a suitable location to provide this type of accommodation. 6.24 The site itself is located adjacent to the built form of Turvey Station and is well related to it. Turvey Station has a concentrated and recognisable built form and comprises a distinct group of buildings and built development. Development on this site would be well related to structure, character and form of the settlement and is distinct from the countryside beyond. 6.25 Turvey Station lies a short distance to the east of Turvey, a large village with a number of local facilities and services. Turvey Station serves as a village end for Turvey and is well located to the village which provides for a variety of local needs including a post office and village store, Public Houses, places of worship, employment, a primary school, and a village hall. In functional terms Turvey Station is viewed as part of Turvey from which it draws its services and is a suitable and sustainable location for new development. 6.26 A site location plan is included at Appendix 1 of these representations. 6.27 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 Turvey/Turvey Station, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should a Neighbourhood Plan not proceed.

7.1 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 that would be as sustainable the Council has acknowledged that opportunities exist to deliver these requirements as part of the ‘Dispersed’ growth strategy. 7.2 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. 7.3 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.

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 planmaking. 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 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. 9.2 We support the Borough’s proposed 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. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 9.3 Revision to strategic policies and additional allocations provided as part of the Review of the Local Plan should ensure that opportunities to sustain and enhance the role of smaller settlements are maximised. This should also be supported by a review of the capacity for growth in order to deliver the requirements for development in each settlement. 9.4 This can be achieved as part of a ‘Dispersed’ spatial option, which the Council has previously determined as equally sustainable when considering levels of growth in the rural area. Greater weight should be given to recognise the cumulative benefits of growth in locations that contribute to meeting local requirements for sustainable development (in terms of accessible social and community infrastructure) and delivery of the Plan’s strategic priorities such as meeting the needs of education. This should be reflected in the Council’s site assessment and site selection process.