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

Object

Representation ID: 8868

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

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
3.3 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.
3.4 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.
3.5 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
3.6 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.
3.7 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
12
3.8 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. This reinforces the benefits of village-related growth in the ‘east’ corridor parishes.

Object

Representation ID: 8869

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraph 1.14 (Scope of the Plan) – Object
3.9 The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.10 As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
3.11 This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
3.12 This sits alongside strategic decisions where direction will be provided by the Framework e.g., implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.13 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.14 The Council’s proposed strategy in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
13
highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
3.15 The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.

Object

Representation ID: 8870

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraphs 1.47-1.48 (Neighbourhood Planning) – Object
3.16 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. Roxton however, declined to prepare a Neighbourhood Plan and development was allocated through the Local Plan. This is relevant to the Council determining the most appropriate approach to site selection and allocation within the Local Plan 2040.
3.17 Within the context of Roxton 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. Given the background to the adopted Local Plan 2030 the Local Plan Review offers a significant opportunity for Bedford Borough Council to lead on the allocation of additional sites or otherwise provide clarity of the requirements of general conformity that any future Neighbourhood Plan for Roxton must satisfy. This includes meeting the objectives for growth within the ‘east’ corridor parishes.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
3.18 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.
3.19 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.
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
14
3.20 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, which includes our client’s site land in Roxton.
3.21 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 and Rural Service Centres.
3.22 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
3.23 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.
3.24 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
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
15
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).
3.25 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).
3.26 In the case of Roxton a requirement figure for the purposes of Neighbourhood Planning should be identified, in accordance with national policy. However, in the absence of a designated Neighbourhood Area for the parish this would alternatively provide the basis for the Borough Council to select the allocation of sites to meet this figure.

Object

Representation ID: 8871

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Section 2 (Draft Vision) – Object
3.27 This section addresses two main themes. It firstly sets out the shortcomings of the Vision in terms of reflecting comprehensive opportunities for sustainable development across the borough. Secondly, it addresses that while there are many positive aspects of outcomes sought under the vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options.
Reasoning
3.28 The draft Vision sets out:
“Well-planned growth supported by appropriate infrastructure and avoiding areas of high flood risk will enable the creation of strong, safe and resilient local communities in environments that facilitate healthy and independent living for all.”
3.29 This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
16
omitting a significant number of the Borough's KSCs and RSCs from the spatial strategy and do not seek to provide for the additional development required to secure balanced communities. It is not proposed to allocate small housing sites in the plan and concern is expressed that this will delay housing delivery in the early part of the plan period.
3.30 The Vision further states:
“Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”
3.31 This would imply a requirement for additional growth, which the preferred options exclude for a significant number of settlements. Also, for Roxton, the previous lack of willingness of the community to prepare a neighbourhood plan is also relevant to achieving the Vision.
3.32 The Vision also fails to reflect that the proposed development strategy is not looking to provide for any additional growth in rural areas as part of an uplift to meet housing needs in full before 2030. This is a significant shortcoming of the strategy and overlooks suitable and deliverable sites that could be prioritised now to meet these increased needs alongside the delivery of other substantial benefits.

Object

Representation ID: 8872

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraph 3.17 and Option 2d – Comment
3.33 These representations endorse the inclusion of the ‘east’ corridor parishes as part of Preferred Option 2d but in practice indicate that this is illustrative of a need for a ‘hybrid’ approach to provide for an appropriate strategy in accordance with national policy and guidance (NPPF2021 paragraph 35(b)).
3.34 These representations conclude that any selected strategy option that does not include growth in the ‘east’ corridor parishes would be unsound and fail to comprise an appropriate strategy or genuine reasonable alternative for the purposes of the Sustainability Appraisal. This is due to soundness issues identified with the delivery of large-scale strategic growth comprising other components of the Council’s Preferred Options.
3.35 The benefits of Option 2d reflect the ability to promote and maximise the benefits of what is in-effect village-related growth at the Rural Service Centre of Roxton, complementing opportunities for sustainable growth within the corridor. Growth at Roxton has been accepted as sustainable in the spatial strategy of the adopted LP2030, and the evidence base for the Local Plan 2040 indicates no in-principle constraint to capacity for further development that
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
17
could not be adequately mitigated.
3.36 The Council’s draft Sustainability Appraisal findings reflect positively on the benefits of ‘east’ corridor parishes within the A421 corridor. The figure of 750 dwellings in the Council’s Preferred Option 2d exceeds the Council’s arbitrary figures applied for the purpose of testing Great Barford, Roxton and Willington as ‘village-related’ growth but would in our view represent a more realistic starting point taking account of the capacity for growth at Roxton and in-particular our client’s site. There is no site-specific justification or settlement-specific justification as to why this figure should be limited to 750 dwellings and why growth at Roxton should be limited to only 35 units.
3.37 The Council’s Preferred Options consultation proposals offers only limited scope to address local requirements for place-making and connectivity as part of a comprehensive strategy. The strategy concentrates on the ‘east’ and ‘south’ transport corridor parishes and it should be noted that additional development Roxton would be in general accordance with objectives of the emerging Oxford-Cambridge Arc Spatial Framework applicable across the settlement hierarchy. 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.
Endorsement of growth at Roxton under Option 2d in the context of a ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’ growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of their capacity to contribute towards sustainable development. The benefits of ‘village-related’ development do not suddenly materialise only where Key Service Centre and Rural Service Centres are located in the A421 corridor and do not evaporate altogether outside of it. The allocation of land in Roxton represents a sustainable opportunity to provide flexibility and choice to the Council’s strategy options as well as sustaining and enhancing the role of the settlement itself.