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

The Council proposes a plan period to 2040. As noted, this will differ from the plan period for the Oxford-Cambridge Arc Spatial Framework (Arc Framework) which is to 2050. Given the Local Plan will need to demonstrate its consistency with the Arc Framework when it becomes national policy in 2023 in order to be found ‘sound’, the Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan. It could seriously undermine the delivery of national policy if they are not reflected in the Development Plan for Bedford Borough. Whilst it is acknowledged this is challenging given both Plans are being prepared simultaneously, effective and on-going joint working is integral to a positively prepared and justified strategy.

In any event, national policy now requires Councils should set a vision that looks at least 30 years ahead when allocating new settlements or significant extensions to existing villages and towns (paragraph 22 of the NPPF). Given the nature of the options presented in this consultation, it would be prudent for the Council to decide now to revise its Plan period to 2050.

The scope of the Plan will need to consider the implications of the recent changes in national policy (NPPF July 2021), and the emerging content of the Arc Spatial Framework.

A Technical Note prepared by Jubb on behalf of Rainier Developments Limited is submitted by email separately.

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
The suitability of Roxton to accommodate modest growth is recognised within the Options identified within the Topic Paper, forming part of Option 2d, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options). Although Option 2d is not considered the best performing option in the Sustainability Appraisal, dispersing housing growth over a wider area than Option 2a has the advantage of enabling the housing requirement to be met earlier in the Plan period. That will have significant economic and social benefits.
Whichever option or mix of options is carried forward as the preferred strategy, villages like Roxton need to accommodate modest growth (i.e. an additional circa 50-75 dwellings) over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs, particularly as it will help to ‘top-up’ the housing requirement during the early part of the Plan period.
Rainier Developments would draw your specific attention to land off Bedford Road, Roxton (ID 776) as a suitable site that would support the delivery of the strategy in contributing circa 70 dwellings towards meeting the housing requirement and affordable housing need. The site adjoins the settlement boundary, is closely inter-related with the physical form of development, and is enclosed by the Bedford Road to the north. There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning.
Separate representations have been made in response to the Site Assessment Consultation on ID 776.

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
The suitability of Roxton to accommodate modest growth is recognised within the Options identified within the Topic Paper, forming part of Option 2d, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options). Although Option 2d is not considered the best performing option in the Sustainability Appraisal, dispersing housing growth over a wider area than Option 2a has the advantage of enabling the housing requirement to be met earlier in the Plan period. That will have significant economic and social benefits.
Whichever option or mix of options is carried forward as the preferred strategy, villages like Roxton need to accommodate modest growth (i.e. an additional circa 50-75 dwellings) over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs, particularly as it will help to ‘top-up’ the housing requirement during the early part of the Plan period.
Rainier Developments would draw your specific attention to land off Bedford Road, Roxton (ID 776) as a suitable site that would support the delivery of the strategy in contributing circa 70 dwellings towards meeting the housing requirement and affordable housing need. The site adjoins the settlement boundary, is closely inter-related with the physical form of development, and is enclosed by the Bedford Road to the north. There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning.
Separate representations have been made in response to the Site Assessment Consultation on ID 776.

In the context of the need to boost housing supply in light of the increased housing requirement (circa 33% increase per annum), the Council should make housing allocations in this Local Plan to avoid unnecessary delay to housing delivery which is required to meet the increased need for this plan period. This is particularly relevant in Roxton where no Neighbourhood Plan has been prepared thus far.

As the consultation acknowledges, the figure of 1,275 dwellings per year is the Local Housing Need and is the starting point. It is also the minimum number of homes needed in accordance with national policy (paragraph 61). The Council need to consider whether a higher figure is necessary in order to address the worsening issue of affordability (with average house prices 8.4 times average earnings), or in order to respond to unmet needs that may arise from neighbouring areas or from the Greater London authorities.
However, more fundamentally, it needs to consider whether delivering the bare minimum number of homes is sufficient to match the intention for Bedford Borough to be at the heart of a national economic priority area as set out within the Oxford-Cambridge Arc Spatial Framework. In order to become one of the most prosperous, innovative and sustainable economic areas in the world, and make a major contribution to national economic recovery, the area will require labour and those people will require affordable homes unless unsustainable patterns of commuting are to prevail. The economic potential of the Arc will not be achieved, or not achieved in a sustainable way, by providing the minimum number of homes needed.
In this regard, it is questioned whether the forecast growth in jobs of 13,200 over the plan period within the LHNA (using the 2019 EEFM data) is now accurate in light of the Government’s intended strategy. The Council should review the LHNA and its anticipated job growth to assess whether there is a need to uplift the local housing need to meet the future needs of jobs and workers.
Further, the planned investment in East-West Rail, in addition to the proposed investment in sustainable infrastructure within the Arc Spatial Framework, similarly provides a strong case for a higher housing need figure than the standard method in order to satisfy the future demand that it will drive for people to live in and around Bedford. Support for a higher figure in this context is set out within the NPPG (Paragraph: 010 Reference ID: 2a-010-20201216).

The Council will need to demonstrate in its evidence base that existing commitments can be delivered within the plan period, and these will also need to be set out within the proposed trajectory as indicated to be provided at paragraph 3.4. The trajectory will of course need to be realistic as required by national policy (NPPF paragraph 73), and should have regard to the evidence from Start to Finish Two (Lichfields Feb 2020).

The Council need to consider the social and economic consequences of a stepped trajectory, namely the impact of unmet housing needs arising within the Borough over the first half of the plan period (i.e. 2020 to 2030). If suitable and deliverable sites are available now in sustainable locations, they should be allocated and the strategy amended to avoid or minimise the need for a stepped trajectory. Housing needs are arising now, and they should be met as soon as possible.
Given the negative consequences for the economy and population, any such policy will need to be clearly justified in order to be found sound. On the basis of the evidence and the availability of suitable and deliverable sites in sustainable locations, it is considered such a policy unlikely to be found sound.

These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
The suitability of Roxton to accommodate modest growth is recognised within the Options identified within the Topic Paper, forming part of Option 2d, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options). Although Option 2d is not considered the best performing option in the Sustainability Appraisal, dispersing housing growth over a wider area than Option 2a has the advantage of enabling the housing requirement to be met earlier in the Plan period. That will have significant economic and social benefits.
Whichever option or mix of options is carried forward as the preferred strategy, villages like Roxton need to accommodate modest growth (i.e. an additional circa 50-75 dwellings) over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
Rainier Developments would draw your specific attention to land off Bedford Road, Roxton (ID 776) as a suitable site that would complement the strategy in this context.