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

Object

Representation ID: 8876

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.6 (Housing Needs of Different Groups / Older People)– Object
2.30 Paragraph 3.6 of the Council’s Consultation Document sets out:
“The LHNA also provides the evidence base to update the policies of the Local Plan 2030 on these matters. Policy 58S Affordable housing and 59S Housing mix will be updated once the viability of the Local Plan as a whole has been tested.”
2.31 Without prejudice to any further evidence our client may submit at future stages of consultation, these representations highlight that the Council’s own emerging evidence indicates an urgent and pressing requirement to address the needs of specialist housing for older people. The Council has failed to incorporate its own evidence of an urgent and substantial level of need into its own testing of strategy options and has further ignored other important material considerations regarding the importance of the sector. Failure to take account of this important element of the Plan’s objectives renders the overall approach to plan preparation unsound: not effective and not consistent with national policy.
Reasoning
2.32 The evidence base generated by the LP2030 on the housing needs for older people is substantially out-of-date and pre-dates the latest version of the NPPF and specific guidance in the NPPG. This reflects the impact of a foreshortened plan period and the Council’s reliance on an objective assessment of housing need substantially below that resulting from the government’s Standard Method. Furthermore, the LP2030 makes no specific provision or allocations to provide sites to deliver the requirements for specialist accommodation.
2.33 The strategic policies of the Plan, with which Neighbourhood Plans under preparation must be in general conformity, provide no specific direction on how the housing needs of older people should be addressed. Neighbourhood Plans ‘made’ or currently under preparation in the Borough have generally not made any specific provision to address this important component of housing need.
2.34 The Local Housing Needs Assessment (LHNA) (Figures 10 and 67), prepared to inform the Council’s draft strategy and policy options, identifies a net need for over 1,500 units of Extra Care accommodation to 2040 (872 ‘owned’ and 632 ‘rented’ units). This level of need is derived from the Housing Learning and Improvement Network (Housing LIN) SHOP resource pack methodology (2012) referred to in Planning Practice Guidance. This level of need is principally a function of low levels of existing supply and very limited recent development of Extra Care for sale within the Borough (contrasting with an oversupply of traditional ‘sheltered’ accommodation).
2.35 Recent Appeal Decisions have reinforced that the notional prevalence rates applied through relevant toolkits should be treated with caution and are likely to provide a minimum starting point. In respect of the 45 units of Extra Care accommodation per 1,000 residents aged 75+ set out within the SHOP toolkit Inspector Stephens opined at Paragraph 40 of the Appeal Decision at Little Sparrows, Sonning Common, South Oxfordshire (PINS Ref: 3265861) that this:
“should be far more ambitious given not only the true tenure split in the District but also what it could mean for the ability to contribute towards addressing the housing crisis”
2.36 This reflects international comparisons with regards the rate of provision for specialist housing for older people and the potential additional benefits associated with freeing up family housing.
2.37 The House of Commons Housing, Communities and Local Government Committee also focuses upon the housing needs of older people in assessing the government’s proposals for ‘The Future of the Planning System in England’ (First Report of Session 2021-221). Paragraph 136 of that Report states:
“There should also be support and encouragement for local authorities to deliver specialist housing, particularly for elderly and people with disabilities. The Government should create a C2R class for retirement communities to ensure clarity in the planning process. There should be a statutory obligation that Local Plans identify sites for specialist housing”
2.38 This recommendation seeks to build upon the existing direction of travel in national policy and guidance. It should, however, be noted that the current Planning Practice Guidance
1 https://committees.parliament.uk/publications/6180/documents/68915/default/
(updated in June 2019) identifies that Plans should consider the allocation of sites in circumstances where an unmet need is identified (ID: 63-013-20190626) and reinforce this with a positive approach towards decision-taking (ID: ID: 63-016-20190626).
2.39 Planning Practice Guidance also provides a non-exhaustive list of considerations for the development of age-friendly places (ID: 63-018-20190626). In terms of the specific locational and scheme requirements for retirement village schemes (including Extra Care) it is important that the site is of a sufficient size to secure a critical mass of services, facilities, and opportunities for care provision. Such schemes typically provide substantial benefits to the wider community in terms of access to social spaces and shared facilities.
2.40 The considerations set out in the relevant PPG can be sustainably addressed as part of one option for a scheme on our client’s land at Green End, which would also enable easy access to services and facilities in the urban area (including pedestrian links and potential arrangements such as lift-sharing and community transport).
Suggested Approach / Remedy
2.41 There is an urgent requirement to update the provision for specialist accommodation for older people set out in Policies 59S and 60 of the Local Plan 2030, which are significantly out-of-date. These pre-date the latest iteration of national policy and guidance and are based upon an indication of a requirement for only 1,400 units of specialist accommodation to 2030 (see paragraph 10.18) as opposed to over 5,000 units to 2040 in the emerging evidence. The current policy position also fails to capture the broad range of provision possible to meet the requirements for specialist accommodation, including the retirement village concept, and thus present an outdated interpretation of the Use Classes Order.
2.42 These factors, taken together, also indicate a significant and urgent requirement to allocate specific sites to meet the specialist housing needs for older people as part of site selection to inform the submission draft Plan. For the reasons set out in these representations a ‘general’ approach that defers opportunities to large-scale strategic sites with long development timeframes will not be effective or consistent with national policy. Additionally, the deferral of site allocations to Neighbourhood Plans is likely to remain ineffective unless very clear direction of the requirement to make provision towards housing for older people is set out in the strategic policies in the Plan.
2.43 As such, our client’s land at Green End, Kempston, represents an appropriate location to satisfy parts of the Council’s substantial need for specialist housing for older people and should be assessed in detail as part of options for the site to be tested in detail at the next stage of plan-making.

Object

Representation ID: 8904

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

2.2 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.
2.3 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. 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
2.4 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).
2.5 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.
2.6 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.
2.7 Paragraph 28 of the NPPF2021 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 and Rural Service Centres.
2.8 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
2.9 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021. 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.
2.10 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, recognises 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).
2.11 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).
2.12 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) whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the Standard Method to 2040.
2.13 Any impacts upon the evidence based 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
2.14 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the NPPF2021. 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’.
2.15 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth. There may be scope to alter the distribution of the housing requirement to Key Service Centres upwards or downwards from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and other potential benefits for development in these settlements relative to their overall potential contribution to LHN.
2.16 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 outside of defined settlements on suitable, previously developed, sites that could contribute towards housing needs in the wider rural area.

Object

Representation ID: 8905

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.26 – 3.28 (Small Sites) –Object
2.17 The Council’s proposed approach to enabling the development of small sites as a source of flexibility in supply and to provide diversity within the construction sector is misconceived and inconsistent with national policy, ineffective and not justified. The Council is simply seeking to ignore the requirements at paragraph 69 of the NPPF2021 and undermine the government’s objectives to support inter alia SME builders, prosperous rural communities, and measures to address affordability.
Reasoning
2.18 The Council seeks to rely on evidence of past and expected future trends in windfall development in place of the requirement in national policy to identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.
2.19 The reasoning for the approach in national policy is simple: the development plan is the most appropriate vehicle to set out positively prepared policies to support the delivery of small sites and enable small and medium developers (who often face the greatest barriers to entry in the sector) to secure implementable planning permissions more easily.
2.20 The Council’s own evidence in the Small Sites Topic Paper demonstrates a year-on-year fall in trends in the completion of small windfall sites against the Local Plan 2030 requirement of 970dpa. This is illustrative of issues affecting the sector. The Council must also be mindful of the fact that more recent policies in the development plan (particularly those within
Neighbourhood Plans) provide a further barrier to bringing forward appropriate proposals on unidentified sites.
2.21 The evidence from past trends fails to support the Council’s contention that windfall supply will provide for 10% of the higher requirement based on minimum annual local housing need for the period 2020 to 2040. The Council relies on expected future trends but the justification for its proposed approach fails for the following reasons:
• The Council’s reference to extant commitments takes no account of any potential lapse rate or double-counting with assumptions of future supply
• Expected trends take no account of changes to Permitted Development Rights (including restrictions upon office-to-residential conversions and a reduction in the number of potentially suitable sites)
• Extant small-site commitments take no account of those that are effectively ‘one-off’ schemes that would not be accessible to the SME sector (e.g., backland plots or subdivision)
• The likely supply from Neighbourhood Plans, which is a tiny proportion of the 2,260 dwellings required from this source and illustrative of these Plans often focusing development on a limited number of challenging sites, is dwarfed by the resulting restrictions on additional growth.
Remedy
2.22 There are some positive aspects to the Council’s evidence base to support growth on small sites, such as the 136 units’ capacity identified in urban areas. In reality we consider that this total should be increased and that in order to achieve the Council’s Preferred Options to include allocation of a further 1,500 units within the urban area it will be necessary to maximise the potential contribution from small sites. The Council’s total of 1,500 is over-and-above extant development plan allocations within the Town Centre that are and will remain significantly constrained. Failure to diversify urban supply without support through the development plan will result in this component of the spatial strategy being unsound.
2.23 The Local Plan 2040 should also offer substantially greater support for the delivery of small sites in rural areas. This advances the case for the strategic policies of the Local Plan 2040:
• Setting out indicative requirements for all settlements within the Borough’s hierarchy (outside of Key Service Centres and Rural Service Centres) to encourage provision for appropriate levels of smaller-scale growth
• Proactively support the delivery of rural exception sites
• Proactively support the re-use and redevelopment of sites in the wider rural area, such as our client’s land at Manor Farm, Knotting
• Where Policy 4S of the Local Plan 2030 is superseded in terms of the scale and
distribution of growth required at Key Service Centres and Rural Service Centres ensure that any increased need for development to be provided through reviews of Neighbourhood Plan also has regard to NPPF2021 paragraph 69
2.24 The opportunity for the Local Plan 2040 and any Neighbourhood Plans to be prepared taking a more flexible approach towards the requirements of national policy is supported in principle.
2.25 For example, where any allocations proposed would offer the opportunity for early delivery and the potential to introduce multiple developers to relevant sites it would be appropriate to treat the 1 hectare threshold pragmatically, recognising that the revised strategy will itself provide substantial opportunities for diversification.

Object

Representation ID: 8906

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.26 The emerging preferred options put forward by the Council continue to 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.
2.27 Representations addressing our client’s interests elsewhere in the Borough endorse a ‘hybrid’ approach making provision for village-related development outside of the ‘east’ and ‘south’ corridor parishes. Reassessment of Option 3c provides an appropriate starting point for such an approach.
2.28 Within this strategy option the Council has applied arbitrary ‘one size fits all’ totals to Key Service Centres and Rural Service Centres but made no provision for a contribution towards the strategy totals from locations outside these settlements e.g., on previously developed rural sites.
2.29 This is inconsistent with the approach to other strategy components where a more flexible approach is applied e.g., non-specific estimates of urban capacity. Utilisation of other appropriate sites would add flexibility to the strategy and reduce any of the harmful effects that the Council associates with testing non-specific levels of village-related growth.

Object

Representation ID: 8908

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 1.10 (alignment with the Spatial Framework)– Comment
2.2 The Council’s Preferred Options published for consultation contend that they draw heavily on the ‘pillars’ of economic development and the natural environment from the emerging Spatial Framework. The representations identify that the Council’s published consultation proposals fail to embrace the comprehensive approach to supporting sustainable development anticipated in the Spatial Framework. Paragraph 1.10 of the consultation document ignores altogether the place-making ‘pillar’ of the Framework while the Preferred Options as a whole are overly reliant on assumptions regarding improvements in strategic-level connectivity. This fails to embrace local opportunities for sustainable development.
Reasoning
2.3 It is surprising, and inconsistent with national policy and the emerging objectives of the Arc Spatial Framework, makes no mention of the connectivity or place-making pillars of the Spatial Framework. Each should be considered of equal importance.
2.4 Specifically, paragraph 4.1 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc places significant emphasis on reducing the need to travel. Connectivity is not just about strategic road/rail links - it means:
“improving communities’ access to the services they need – like a good quality, sustainable water supply and broadband, schools, cycle lanes and healthcare, as part of a great approach to place-making.”
2.5 Paragraph 4.4 also states the importance of recognising the needs of an ageing population in terms of service delivery. At Paragraph 4.5 the document goes on to explain:
“the policies of the Framework will be used to create a clear infrastructure plan giving communities access to the public services they need – including education and health”.
2.6 The settlement hierarchy in Bedford Borough means that Rural Service Centres and Key Service Centres across the authority have a key role in delivering these requirements for
sustainable communities and serving a wider rural hinterland – both in terms of immediate needs and their role throughout the plan period. The strategy in the Local Plan 2030 has deferred important decisions relating to these priorities both in terms of avoiding the reclassification of centres such as Oakley and in placing the requirement to allocate sites upon Neighbourhood Plans. Priorities have therefore not been addressed and in any event the current strategy has only sought to address a foreshortened period to 2030.
Remedy
2.7 The Council’s Preferred Options consultation proposals offer no scope to address these local requirements for place-making and connectivity as part of a comprehensive strategy. This is as a result of identifying no requirement for additional village-related growth outside of the ‘east’ or ‘south’ transport corridor parishes. Opportunities for sustainable development in accordance with these requirements (and the objectives of the emerging Spatial Framework) must be embraced both in the period to 2030 (to address the immediate uplift in the need for growth) and across the entire Plan period to sustain the role and function of the Borough’s most sustainable settlements.

Object

Representation ID: 8909

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Section 2 (Draft Vision) – Comment
2.8 The recognition of tourism and recreation as part of the Council’s Vision to 2040 is supported in principle as is recognition that enhancement to the Borough’s green infrastructure network and natural environment are key components of this offer. The delivery of new multi-functional green spaces and Country Parks is also appropriate in principle as a means of securing these benefits.
2.9 The principle of these objectives is supported but is reliant on flexibly supporting diverse opportunities for development across the settlement hierarchy. There are a substantial number of centres where the level of development identified is sufficient to secure the opportunities identified.
2.10 This is reinforced by the ‘Themes’ underpinning the Plan (notably Theme 1 ‘Greener’ and Theme 4 ‘Better Places’). However, we consider that the approach to the preparation of strategy options and in-particular focusing potential benefits on large-scale strategic growth in the Milton Keynes-Bedford Waterway south of the town (and at existing commitments in Brickhill) means that the Vision is not effective and not positively prepared.
2.11 This principally results from the failure to identify a contribution from any village-related growth outside of the ‘east’ and ‘south’ corridor parishes as part of the Council’s Preferred Options. This fails to recognise that at locations in the north of the Borough the aims of the Council’s Vision can be secured sustainably through appropriate village extensions, complemented by opportunities for rural recreation and tourism such as our client’s land at Radwell Lakes.

Object

Representation ID: 8910

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.12 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.
2.13 Recreation and leisure growth are focused on either historic strategies or within the Council’s urban centres, including Bedford Town.
2.14 In setting out options within the Council’s Development Strategy Topic Paper the Council makes no allowance for the potential delivery of green infrastructure and benefits for tourism, recreation and leisure associated with each proposed approach. This means that the potential positive effects for village-related growth north of the Borough have not been assessed in site-specific or settlement-specific detail prior to rejecting this as component of the strategy. This is compounded by failing to assess other opportunities for tourism and recreation outside of the Council’s preferred strategic locations.
2.15 Embracing these opportunities is necessary to ensure that the selected strategy option is consistent with national policy to support a prosperous rural economy. Specifically, Paragraph 84(c) of the NPPF2021 notes that policies and decisions should enable sustainable rural tourism and leisure developments which respect the character of the countryside. Paragraph 85 of the Framework recognises that sites suitable to meet these needs will not necessarily be within or adjacent existing settlements but warrant support where improvements to non-car access ca be secured and severe impacts on the highway network can be avoided.
2.16 The Site Land off Moor End Lane, Radwell (Radwell Lakes) is unique in the Borough and represents an optimal location to provide a bespoke leisure and recreation venue. The
development of this facility would support healthier communities, complement the leisure infrastructure available to current and future residents.
Remedy
2.17 Therefore, as part of a ‘hybrid’ approach recommended by our clients as an appropriate strategy it is necessary to reassess levels of development within the northern KSC and RSC, where there is both demand for development and also the available sites to aid in the delivery of housing post 2030. These strategy options should also aim to support rural tourism and rural leisure opportunities. The Site Land off Moor End Lane, Radwell is an exceptional asset in the countryside. It offers an optimal location to provide a bespoke outdoor sports, leisure and recreation facilities potentially linked with innovative visitor accommodation. Currently, there are certain projects referred to in the Local Plan, but these only cover a small number of parcels mainly south of the Borough.
2.18 This has important implications for the assessment of effects in the Council’s draft Sustainability Appraisal. For example, the ‘uncertain’ findings for rejected Option 3c incorporating village-related growth for Objective 7 (encourage physical activity) and Option 13 (community facilities) should be amended in recognition of the potential benefits and opportunities to be considered as part of site selection. Such an approach would also allow the identification of suitable opportunities for biodiversity enhancement and mitigation to overcome potential negative effects that the Council identifies as part of more dispersed approaches.

Object

Representation ID: 8911

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy TC2 (Out of centre development) – Comment
2.1 The policy sets out that new retail, leisure, and office development is required to locate in Bedford town centre, Kempston district centre and the local centres as defined in Policy TC1S – Hierarchy of town centres. If no suitable sites are available, edge of centre locations should be considered and only if suitable sites are not available should out of centre sites be considered. Principally we support Policy TC2 in terms of its support for out-of-centre development subject to an assessment of potential impacts. However, in terms of the opportunities and development of tourism and leisure uses required to achieve the Council’s Vision and Objectives the policy fails to provide sufficient flexibility in terms of how these should be assessed for the purposes of decision-taking or achieved as part of the wider strategy.
2.2 In terms of opportunities for rural tourism and recreation including the creation of green infrastructure, these aims should be secured through the allocation of our client’s strategic opportunity at Radwell Lakes.
2.3 Should the land not be selected for allocation Policy TC2 should be modified to introduce exceptions for retail and leisure development in order to provide support for development (such as rural tourism and recreation) that is not compatible with Town Centre locations but would complement the Plan’s wider strategy.
2.4 This exception should be provided subject to suitably worded policy criteria (such as arrangements for access and controls over future use) to ensure no adverse impact on Town Centre locations. Such criteria could be satisfied in the case of our client’s land at Radwell Lakes while also enhancing the benefits of other village-related growth.
2.5 This is necessary in order to provide flexibility so that the Local Plan can respond quickly to a changing commercial market.

Object

Representation ID: 8988

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Comments on the Proposed Approach and Supporting Evidence
The section of the representations provides observations on the soundness of the Council’s
overall approach towards preparation of the Local Plan 2040 and identification of the strategic
priorities it is required to address. Comments specifically relate to Chapters 1 and 2 of the
consultation document.

Paragraph 1.5 (proposed plan period)– Object
3.2 Definition of the proposed Plan period underpinning the Council’s Preferred Options has
been rendered inconsistent with national policy following publication of the 2021 version of
the NPPF.

Reasoning
The larger-scale approaches to development (including new settlements) that the Council
has identified as part of its Preferred Options accord with the circumstances that national
policy identifies for considering a minimum 30-year horizon, to take account of longer
timescales for development.


Paragraph 1.2 of the ‘Creating a Vision for the Ox-Cam Arc’ consultation document also
confirms that the Spatial Framework will extend to 2050 and beyond. Preparation of the
Bedford Local Plan 2040 should be undertaken consistently with this aim.


The proposed Plan period of 2020 to 2040, particularly when read in the context of the
Council’s Preferred Options resulting in a further delay to meeting development needs in full
(until at least 2030) will generate a requirement for further, successive, reviews and is setting
the plan up to fail.

Remedy
Bedford Borough Council should not wait for transitional arrangements upon introduction of
the Framework to have to undertake yet another review that will need to consider the shortfall
in meeting needs and addressing strategic priorities to 2030. Realistically, as a result of the
scale and pattern of the Preferred Options proposed, delays to timescales for development
are also likely to result in delays to meeting needs in full between 2030 and 2040.

Those parts of the Council’s Preferred Options relying on larger-scale development should
be profiled to look further ahead to 2050.

This reemphasises that in terms of the soundness requirements for preparation of the Local
Plan 2040 the Council’s proposed approach must also fully embrace those sustainable
opportunities to meet the increased requirements for growth in the immediate term and
enable this through the prioritisation of suitable and deliverable sites as part of a ‘hybrid’
strategy.

Object

Representation ID: 8989

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s Preferred Options published for consultation contend that they draw heavily
on the ‘pillars’ of economic development and the natural environment from the emerging
Spatial Framework. The representations identify that the Council’s published consultation
proposals fail to embrace the comprehensive approach to supporting sustainable
development anticipated in the Spatial Framework. Paragraph 1.10 of the consultation
document ignores altogether the place-making ‘pillar’ of the Framework while the Preferred
Options as a whole are overly reliant on assumptions regarding improvements in strategic level
connectivity. This fails to embrace local opportunities for sustainable development.

Reasoning
It is surprising, and inconsistent with national policy and the emerging objectives of the Arc
Spatial Framework, that the consultation proposals make no mention of the connectivity or
place-making pillars of the Spatial Framework. Each should be considered of equal
importance.

Specifically, paragraph 4.1 of the consultation document ‘Creating a Vision for the Oxford-
Cambridge Arc places significant emphasis on reducing the need to travel. Connectivity is
not just about strategic road/rail links - it means:
“improving communities’ access to the services they need – like a good quality,
sustainable water supply and broadband, schools, cycle lanes and healthcare, as part of
a great approach to place-making.”

Paragraph 4.4 also states the importance of recognising the needs of an ageing population
in terms of service delivery. At Paragraph 4.5 the document goes on to explain:
“the policies of the Framework will be used to create a clear infrastructure plan giving
communities access to the public services they need – including education and health”

The settlement hierarchy in Bedford Borough means that Rural Service Centres and Key
Service Centres across the Authority have a key role in delivering these requirements for
sustainable communities and serving a wider rural hinterland – both in terms of immediate
needs and their role throughout the Plan period. The strategy in the Local Plan 2030 has
deferred important decisions relating to these priorities both in terms of avoiding the
reclassification of centres such as Oakley and in placing the requirement to allocate sites
upon Neighbourhood Plans. Priorities have therefore not been addressed and in any event
the current strategy has only sought to address a foreshortened period to 2030.

Remedy
The Council’s Preferred Options consultation proposals offer no scope to address these local
requirements for place-making and connectivity as part of a comprehensive ‘hybrid’ strategy.
This is as a result of identifying no requirement for additional village-related growth outside
of the ‘east’ or ‘south’ transport corridor parishes. Opportunities for sustainable development
in accordance with these requirements (and the objectives of the emerging Spatial
Framework) must be embraced both in the period to 2030 (to address the immediate uplift in
the need for growth) and across the entire Plan period to sustain the role and function of the
Borough’s most sustainable settlements.