Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 6182

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s Approach to the Assessing Settlement Hierarchy – Objection
Reasoning
2.2 The Council’s work to justify the selected Preferred Options is at a relatively early stage with significant ‘gaps’ in the evidence presented – particularly in terms of development timescales, infrastructure delivery and viability. The Council notes, as follows:
• Infrastructure Delivery Plan – to be prepared alongside site allocations
• Settlement Hierarchy (September 2018) – review underway
• Plan-wide Viability Assessment – yet to be commissioned
2.3 The absence of these documents, and in-particular completion of the review of the Settlement Hierarchy, means that the exclusion of Oakley from the Council’s Preferred Options can be demonstrated to be unsound – not effective, not consistent with national policy and not justified.
2.4 The Council’s approach to the assessment of the existing settlement hierarchy is flawed as it fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available.
2.5 Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by public transport.
2.6 Oakley includes local shopping, significant employment opportunities and has both a Primary and Secondary School. As such, Oakley serves a wider catchment area and, in this context,
it is a reasonable alternative to consider a higher level of growth that the 25-50 homes band proposed under the adopted Plan.
2.7 The key issue with the council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the Settlement Hierarchy.
2.8 As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth.
2.9 The shortcomings of this finding are exacerbated because strategic priorities relating to the requirements for social infrastructure (notably education) were deferred rather than dealt with in the Local Plan 2030. This is contrary to the requirements of national policy (NPPF2021 paragraph 20(c)).
2.10 The current Development Plan (including the Oakley Neighbourhood Plan) makes no provision for the expansion of Lincroft Academy that is required and is a function of the growth that the current spatial strategy supports across other Key Service Centres without Secondary School provision (including Clapham and Bromham).
2.11 Addressing these current unmet strategic priorities together with providing a positive approach towards the longer-term requirements for school infrastructure would be most effectively supported by reclassification of Oakley’s role in the settlement hierarchy to reflect its importance to the wider rural area (and strong links to the urban area).
Remedy
2.12 An appropriate remedy for this would be to complete a review of the preferred options within the Local Plan 2040, treat Oakley specifically as a Key Service Centre and recognise that the area has missed out on potential growth to meet key infrastructure requirements as part of the approach to preparation of the Local Plan 2030.

Object

Representation ID: 6184

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 1.11 and Paragraphs 3.1 – 3.3 (Local Housing Need and Levels of Growth)– Comment
2.13 Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the Government’s Standard Method provides the starting point for assessment of the number of homes to be provided through Plan-making. Positive Plan-making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the Standard Method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.
2.14 It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.
Reasoning
2.15 Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the Standard Method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:
• “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
• setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”
2.16 The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.
2.17 In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.
2.18 In-particular, the Council’s Employment Topic Paper:
• Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
• Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
• It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting - the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
• It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)
Remedy
2.19 Failure to take account of these factors means that the Local Plan 2040 is more likely to result in conflict with the emerging priorities of the Arc Spatial Framework and it is recommended that a range of jobs-led scenarios are tested prior to determining the housing requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 6185

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 3.8 (Level of Employment Growth) – Comment
2.20 The Council’s conclusions in the Employment Land Topic Paper to take account of the limited opportunities for high density office development and the majority of demand from within lower density business parks are generally supported.
2.21 It is recognised that the Council’s requirement for a minimum additional allocation of 123ha employment land represents an ambitious target and takes account of relatively limited existing supply. However, the approach to identify the overall land required cannot be considered sound without undertaking more detailed analysis of the potential jobs growth and floorspace needs associated with testing a wider range of jobs forecasts.

Object

Representation ID: 6186

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.22 The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the borough.
2.23 In terms of meeting the needs for economic development the Council’s Preferred Options cannot be considered justified, effective, or positively prepared. This is principally due to an overreliance on the allocation and delivery of large-scale business parks (as summarised at paragraph 6.8 of the Consultation Document. Even allowing for up to three large business parks the Council acknowledges: “the remaining 63 ha should be allocated in smaller sites which are more likely to be attractive for office and general industry purposes.”
2.24 The Council’s Preferred Options are not sufficiently flexible to provide for the range and type of sites required, part of which could be met by our client’s land at Highfield Road. Specifically, the Council is reliant on the delivery of New Settlements and rail-based growth where the availability of land for economic development is uncertain and would have long lead-in timeframes. Particularly for proposed components of growth at Stewartby and Kempston Hardwick the Council is reliant upon land currently being promoted for employment use being brought forward for housing instead. This level of uncertainty is not the basis for sound Plan-making or providing support for the Plan’s priorities regarding economic development.
2.25 The Council’s draft Sustainability Appraisal findings recognise this, where Option 3c (including village-related growth) achieves the same assessment of Positive effects for SA Objective 5 (economic development) as the Council’s Preferred Options. This is a function of the diverse range of local employment opportunities in existing Rural Service Centres (14ha – including our client’s land at Oakley) providing opportunities for the creation of balanced communities. In the case of Oakley, concerns with the assessment findings relating to strategic road access and the potential for clustering are overcome due to proximity to the A6 and existing commercial development at Highfield Park.
2.26 Support for additional opportunities for economic development at sustainable locations in the hierarchy is thus consistent with the Plan’s overall objectives and essential to achieve a sound strategy. The Council should thus adopt a ‘hybrid’ approach to strategy options for both economic and residential development to overcome the soundness concerns identified.

Object

Representation ID: 6187

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy E1S (Amount and Distribution of Employment Development) – Comment
2.1 The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended Plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
2.2 However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in Key Service Centres and Rural Service Centres. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
2.3 Our client’s site at Highfield Road, Oakley, would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters (including access, ecology, and landscape). these parameters would be satisfied.
2.4 Additionally, and should our client’s land not be allocated, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the expansion and intensification of existing safeguarded employment uses within suitably located adjacent sites.
2.5 Paragraph 6.12 of the Council’s consultation document is also noted with regards recent changes to the Use Classes Order. As well as amending policies within the existing LP2030 it is necessary that criteria (i) and (ii) of proposed Policy E1S also recognise that support for economic development in accordance with the strategy, and on unallocated sites, extends across Use Classes B2, B8 and Class E. Criteria (ii), as drafted, refers only to ‘B-uses’. It is not considered necessary for suitable opportunities to be limited only to ‘business’ uses within Class E as suggested by the Council’s paragraph 6.12.
2.6 This is contrary to the flexibility sought by the changes to the Use Classes Order. This approach is also ineffective, as it would not apply to existing lawful former B1 uses within existing employment areas would in most cases benefit from opportunities to provide a wider range of commercial uses under Permitted Development Rights. This could, for example, in principle allow a more diverse range of occupiers at the existing Highfield Park site, commensurate with its location well-related to the settlement of Oakley and wider transport network. The same flexibility should be applied to the Council’s policy criteria when assessing new development proposals.

Object

Representation ID: 6545

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

1.11 and Paragraphs 3.1 – 3.3 (Local Housing Need and Levels of Growth)– Comment
2.2 Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the government’s Standard Method provides the starting point for assessment of the number of homes to be provided through plan-making. Positive plan-making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the Standard Method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.
2.3 It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.
Reasoning
2.4 Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the Standard Method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:
• “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
• setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”
2.5 The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.
2.6 In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.
2.7 In-particular, the Council’s Employment Topic Paper:
• Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
• Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
• It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting - the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
• It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)
Remedy
2.8 Failure to take account of these factors means that the Local Plan 2040 is more likely to result in conflict with the emerging priorities of the Arc Spatial Framework and it is recommended that a range of jobs-led scenarios are tested prior to determining the housing requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 6547

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 3.8 (Level of Employment Growth) – Comment
2.9 The Council’s conclusions in the Employment Land Topic Paper to take account of the limited opportunities for high density office development and the majority of demand from within lower density business parks are generally supported.
2.10 It is recognised that the Council’s requirement for a minimum additional allocation of 123ha employment land represents an ambitious target and takes account of relatively limited existing supply. However, the approach to identify the overall land required cannot be considered sound without undertaking more detailed analysis of the potential jobs growth and floorspace needs associated with testing a wider range of jobs forecasts.

Object

Representation ID: 6551

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.11 The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the Borough.
2.12 In terms of meeting the needs for economic development the Council’s Preferred Options cannot be considered justified, effective, or positively prepared. This is principally due to an overreliance on the allocation and delivery of large-scale business parks (as summarised at paragraph 6.8 of the Consultation Document. Even allowing for up to three large business parks the Council acknowledges: “the remaining 63 ha should be allocated in smaller sites which are more likely to be attractive for office and general industry purposes.”
2.13 The Council’s Preferred Options are not sufficiently flexible to provide for the range and type of sites required, part of which could be met by our client’s land at Rushden Road, Milton Ernest through the expansion of an existing employment use. Specifically, the Council is reliant on the delivery of New Settlements and rail-based growth where the availability of land for economic development is uncertain and would have long lead-in timeframes. Particularly for proposed components of growth at Stewartby and Kempston Hardwick the Council is reliant upon land currently being promoted for employment use being brought forward for housing instead. This level of uncertainty is not the basis for sound plan-making or providing support for the Plan’s priorities regarding economic development.
2.14 The Council’s draft Sustainability Appraisal findings recognise this, where Option 3c (including village-related growth) achieves the same assessment of Positive effects for SA Objective 5 (economic development) as the Council’s Preferred Options. This is a function of the diverse range of local employment opportunities in existing Rural Service Centres (14ha – which it must be assumed includes existing provision at Milton Ernest) providing opportunities for the creation of balanced communities.
2.15 In the case of Milton Ernest, concerns with the assessment findings relating to strategic road access and the potential for clustering are overcome due to proximity to the A6 and existing employment activity within the site.
2.16 Support for additional opportunities for economic development at sustainable locations in the hierarchy is thus consistent with the Plan’s overall objectives and essential to achieve a sound strategy. The Council should thus adopt a ‘hybrid’ approach to strategy options for both economic and residential development to overcome the soundness concerns identified.

Object

Representation ID: 6553

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy E1S (Amount and Distribution of Employment Development) – Comment
2.1 The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
2.2 However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in Key Service Centres and Rural Service Centres. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
2.3 Our client’s site at Rushden Road, Milton Ernest, would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters (including access, ecology, and landscape). these parameters would be satisfied. Criteria (i) should be modified to reflect that the Development Strategy supports the expansion and intensification of existing sites.
2.4 Additionally, and should our client’s land not be allocated or specifically designated within the Policies Map, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the expansion and intensification of existing safeguarded employment uses within suitably located adjacent sites.

Object

Representation ID: 8392

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.

These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030 and beyond. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ Plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford and recently at Sharnbrook).

At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with Parish Councils to meet additional requirements for growth where a range of suitable sites are identified.

This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.

Paragraph 28 of the Framework reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres, Rural Service Centres. The Council’s options test no distribution of requirements to other defined settlements whatsoever, which continues to overlook opportunities for sustainable settlements such as Felmersham to make a commensurate contribution towards the increased needs for development in the period to 2030 and beyond.

This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
The Council’s proposed approach is contrary to paragraphs 66 and 67 of the Framework. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.

This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the Neighbourhood Plan area and should minimise the risk of Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509).

The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the Government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened Plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of Plan-making for the LP2030).

It follows that the process for calculation of any indicative requirement would therefore materially and significantly exceed the evidence base for the LP2030 and the figures in Policy 4S. By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs and whether relating to settlements listed in Policy 4S or not such as in Felmersham) would need to be considered in the context of the overall result of the Standard Method to 2040.

Any impacts upon the evidence base for emerging Neighbourhood Plans must be read alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary to review and update a Neighbourhood Plan’ and states in relation to the above issues:
“There is no requirement to review or update a Neighbourhood Plan. However, policies in a Neighbourhood Plan may become out of date, for example if they conflict with policies in a Local Plan covering the neighbourhood area that is adopted after the making of the Neighbourhood Plan. In such cases, the more recent plan policy takes precedence.”
Remedy
The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the Framework. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the Plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.

Outside of the approach to identification of a housing requirement for Key Service Centres and Rural Service Centres the Council should adopt a flexible approach to supporting development opportunities at other defined settlements such as Felmersham in order to sustain and enhance their role. This is necessary to reflect the longer-term Plan period to 2040 and that such settlements were omitted from provision towards the scale and distribution of growth required to support the LP2030.