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

Object

Representation ID: 4923

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

There is a complex and inter related strategic plan making context to Bedford in light of the Oxford – Cambridge Arc. The Government’s commitment to the Arc in terms of growth, spatial planning and infrastructure is well documented, and it is regrettable that Arc wide plan making has been so significantly delayed, since the clearly preferred position is that the Arc should inform the Bedford Local Plan 2040.
Notwithstanding, we recognise the importance – embedded in the Local Plan 2030 – in Bedford progressing a Local Plan review and on balance it is appropriate that Bedford continues to progress a plan review despite the sequencing difficulties vis a vis the Arc plan making process.
In this context, we would strongly recommend that the Local Plan 2040 be the subject of an early review policy so as to ensure that the issue of sequencing with the Arc is quickly brought back in to line such that strategic/regional planning informs local planning. We recognise that the Local Plan 2040 will, under current NPPF requirements, be the subject of a 5-year review. However, this requirement may change through subsequent revisions to the NPPF, whilst the need for a 5-year review is not a binding whole plan review – NPPF paragraph 33 makes clear that the requirement is to “… review to assess whether they need updating at least once every 5 years”.
The Local Plan 2030 is the subject of an early plan review policy which the Council have accepted on the basis of strategic planning issues (in the case of the Local Plan 2030 issues relating to the standard methodology for calculating housing need). As such adopting an early review policy in the Local Plan 2040 would simply follow the current accepted approach to dealing with strategic planning issues.

Object

Representation ID: 4924

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date. The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.

Object

Representation ID: 4925

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We have no specific comments to make in relation to the Issues and Options Consultation Summary and Responses. However, we would note – in support of our comments in relation to the Development Strategy Topic Paper – that a number of respondents at Issues and Options stage made reference to the need for more and/or different combinations of strategy options to be considered.

Object

Representation ID: 4926

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our responses to the Site Assessment Pro formas. These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
Finally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.

Object

Representation ID: 4928

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We have submitted a series of sites to the Council as part of the call for sites exercise. We have reviewed the pro formas prepared by the Council and have the following observations to make. The site references below are taken from the site pro formas for ease of cross referencing.
[Comments saved separately against site number.]

Object

Representation ID: 4929

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We raise significant concerns in relation to the potential for a stepped trajectory to be taken forward in the Local Plan 2040.
The effect of a stepped trajectory, deferring the delivery of the standard methodology until 2030, is to significantly undershoot on the delivery of annual housing need. In itself this is a significant failure, but in this instance the significant adverse impacts are compounded by a Local Plan adopted based on a low locally derived housing need future and therefore already under delivering against actual housing need.
This means that real people in real need now cannot access the housing market because of the lack of housing, affordability ratios will significantly increase and those people on the housing waiting list will also be unable to access affordable housing given that the primary source of affordable housing is from open market housing sites.
A stepped trajectory runs counter to the provisions of Policy 1S of the Local Plan 2030, a policy put in place to ensure an immediate plan review so as to meet the requirements of the standard methodology. If put in to effect, a stepped trajectory would mean that for Bedford the standard methodology will not take effect until approximately 12 years after the standard methodology was first brought in, which by any measure is wholly inappropriate and unjustified.
It cannot be said that the Council do not have the range of smaller and medium sized sites to enable a smooth rather than stepped trajectory – a significant number of the 430 call for sites submissions are capable of being brought forward without significant on or off site infrastructure. This basket of sites can be delivered without delay and do not justify a stepped trajectory.
Paragraph 3.3 of the Local Plan 2040 refers to the considerable challenges in meeting the requirements of the standard methodology. Those challenges will only increase if a stepped trajectory is put in place, since the second half of the plan period will require on an annual basis housing delivery far higher than even the standard methodology.

Object

Representation ID: 4930

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

Option 2a Development in and around the urban area, plus A421 transport corridor with rail based growth parishes and southern parishes
We raise no specific objections to Option 2a. We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
Option 2b Development in and around the urban area, plus A421 transport corridor with rail based growth parishes and southern parishes, plus one new settlement
We raise no specific objections to specific elements contained in Option 2b, relating to proposals adjoining the urban area and transport corridor.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is marginally less reliant on the rail corridor than Option 2a and as a result on the face of it is a superior option – however the introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2b were it to be advanced with a new settlement as part of the overall strategy.
Option 2c Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements
We raise strong objections to Option 2c.
We would question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is heavily reliant new settlements. Given how poorly new settlements fair in the assessments set out in the evidence base this option cannot, by some margin, be considered to be the most appropriate option when considered against the reasonably alternatives. It is also the case that new settlements will inevitably challenge the ability to deliver the (higher) standard method in the early phases of the plan which – as we have set out elsewhere in our submissions – is vital to the success of the Local Plan Review.
Option 2d Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, southern parishes and east parishes, plus one new settlement
We raise no specific objections to specific elements contained in Option 2d, relating to proposals adjoining the urban area, transport corridor south and transport corridor east.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
The introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2d were it to be advanced with a new settlement as part of the overall strategy.

Object

Representation ID: 4933

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We do not raise any significant concerns in relation to Policy NE1, recognising the provisions of the forthcoming Environment Bill. However, the policy could be enhanced by making reference to applying the DEFRA metric as a means to benchmarking the baseline position with regard to environmental quality, and as a means to assessing the contribution that biodiversity enhancements make. This will provide for a consistent approach, and provide those bringing forward housing and other developments with certainty as to the approach to be taken.
As a separate observation, as drafted Policy NE1 makes reference to enhancing or creating off site habitats “in some circumstances”. The policy should be amended to make clear that off-site environmental net gain is an appropriate solution in all circumstances and may in fact lead to the creation of a greater environmental net gain than would otherwise be achieved on site – thus furthering the objectives behind the policy.

Object

Representation ID: 4935

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.