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

Object

Representation ID: 6154

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Strategic Planning Matters and the Duty to Cooperate
The consultation documents say surprisingly little about strategic planning matters or the position in respect
of cooperation discussions across local authority boundaries.
Strategic policy-making authorities are required to cooperate with each other, and other bodies, when
preparing, or supporting the preparation of policies which address strategic matters. This includes those
policies contained in local plans.
Section 19 of the Planning and Compulsory Purchase Act 2004 relates to the preparation of local
development documents. Section 19 (1B) states:
“Each local planning authority must identify the strategic priorities for the development and use of land in the
authority's area.”
It is not obvious as to how this emerging Local Plan will comply with this.
Paragraph 24 of NPPF (2021) states:
“Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each
other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.”
The duty to cooperate is a legal test that requires cooperation between local planning authorities and other
public bodies to maximise the effectiveness of policies for strategic matters in Local Plans. It is separate from
but related to the Local Plan test of soundness.
The statutory duty to co-operate is found in section 33A - Duty to co-operate in relation to planning of
sustainable development, of the Planning and Compulsory Purchase Act 2004.
The following is a quote from sub-section 4 of 33A.
“(4) For the purposes of subsection (3), each of the following is a “strategic matter”—
(a) sustainable development or use of land that has or would have a significant impact on at least two
planning areas, including (in particular) sustainable development or use of land for or in connection with
infrastructure that is strategic and has or would have a significant impact on at least two planning areas, and
(b) sustainable development or use of land in a two-tier area if the development or use—
(i) is a county matter, or
(ii) has or would have a significant impact on a county matter.”
Paragraph 17 of the NPPF requires local planning authorities to prepare a development plan that includes
strategic policies to address each local planning authority’s priorities for the development and use of land in
its area. These strategic policies can be produced in different ways, depending on the issues and
opportunities facing each area, for example through a joint or individual local plan.
It would be useful to see an explanation on this prior to the next consultation. If the Council considers that
the Local Plan does not contain any of the strategic matters laid out under the 2004 Act then this should be
explained. There are examples where Local Plans have not been successful at examination because of this
matter, for example St Albans City and District.
Timescales including Plan Period
We agree that the 2030 Local Plan needs to be reviewed and for a new local plan to be prepared.
We note at paragraph 1.1 that the update to the local plan is described as having to reflect emerging national
policies for the Oxford to Cambridge Arc and that Policy 1 of the Local Plan 2030 requires that the review is
progressed swiftly, with the submission of the plan to Government for examination by January 2023 so that
examination in public can commence. We consider an ambitious timescale is necessary here and would
question whether submission in January 2023 at the earliest, as identified in the January 2021 Local
Development Scheme, is sufficiently ambitious. This would only bring about adoption of the new local plan at
the end of 2023 at the earliest.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15 year period
from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising
from major improvements in infrastructure. Where larger scale developments such as new settlements or
significant extensions to existing villages and towns form part of the strategy for the area, policies should be
set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for
delivery.
It seems likely that this emerging new local plan will include larger scale development of at least one of the
examples provided under paragraph 22 which suggests that whilst the proposed plan period to 2040 can be
seen to be reasonable, the local plan should include a vision that looks further ahead to 2050 or beyond.
The Tests of Soundness
It is acknowledged that this consultation does not require consultation responses to comment against the
tests of soundness found at section 3 plan-making of the NPPF (2021) but it is nonetheless relevant to have
these in mind now ahead of preparation of the submission version local plan.
Monitoring and Review
Paragraphs 31 to 33 of the NPPF (2021) provides policy guidance on preparing and reviewing plans. Whilst
it is acknowledged that reviews at least every five years are a legal requirement for all local plans under
Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012), it is still
necessary for a Local Plan to contain proposals for monitoring against targets and conditions that are
envisaged to give rise to a review ahead of the requirement under the 2012 Regulations.

Object

Representation ID: 6155

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Scope of the Local Plan Review
We do not agree with the following statement at paragraph 1.14:
“The Local Plan 2040 will be a partial update of existing policies. The Local Plan 2030 was adopted only last
year and the vast majority of its policies are up to date and do not need to change. Remaining policies in the
earlier Allocations and Designations Local Plan have been reviewed and, in the majority of cases, they
remain fit for purpose and similarly do not need to change at this time.”
We consider it is appropriate to undertake a full review and to seek to prepare a new local plan which will
supersede the existing local plan comprising the vision, strategy, policies, allocations and designations. This
will provide clarity on local planning at the Borough level in one document. To seek to undertake only a
partial update and to retain parts of past plans risks multiple policy documents for the Borough in addition to
the emerging Oxford-Cambridge Spatial Framework and in some locations in the Borough there are
neighbourhood plans.
We request that the plan review is full and seeks to replace all existing development plan documents
prepared by the Borough Council for the Borough of Bedford.

Object

Representation ID: 6156

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Vision and Objectives
The vision to the end of the plan period, which we assume is 2040 as this is not stated in the vision, is overly
long and needs to be refined.
Paragraph 15 of the NPPF requires succinct and up-to-date plans that provide a positive vision for the future
of each area; a framework for addressing housing needs and other economic, social and environmental
priorities; and a platform for local people to shape their surroundings. More should be made of local
distinctiveness in the vision for the Borough in 20 plus years from now.
We would expect to see inclusion of provision of new homes for all including the provision of affordable
homes within the vision.

Object

Representation ID: 6157

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Theme 1: Greener, should clearly define what is meant by the term ‘net zero carbon emissions borough’.

Object

Representation ID: 6158

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Growth and Spatial Strategy
Paragraph 3.1 in the consultation local plan, states:
“Government guidance sets out a standard method for calculating future housing requirements, which the
Council must follow. As a result of the government’s recent revisions to the standard method, the figure for
Bedford borough currently is 1,275 dwellings per year, giving a total of 25,500 dwellings for the 20 year
period from 2020 to 2040. This is the current starting point for the local plan housing requirement.”
Paragraph 3.2 goes on to state that the new local plan will need to allocate land to provide a minimum of
12,500 new dwellings. This follows deductions for existing commitments and a windfall allowance. The
minimum 12,500 dwellings represents just under 10 years of supply under the minimum local housing need.
This is not soundly based because it does not follow publication of a review of existing commitments to know
whether these new homes will be delivered as envisaged. There is no delivery trajectory or forecast included
within the consultation version of the local plan and there should be.
The December 2020 Indicative Housing Need for Bedford Borough published by the Government identified a
figure of 1,305 dwellings per year. As the Planning Practice Guidance states at 2a-010 this is just the starting
point which is often described as the minimum. There needs to be an explanation of what options the
Council has looked at and discounted for whatever reason within the consultation document. The Council will
need to explain whether there is sufficient housing being proposed to support future economic growth,
especially given the location within the Oxford-Cambridge Arc. We acknowledge that the new local plan and
the spatial framework are not entirely aligned in terms of timescales but nonetheless it is important for the
emerging new local plan to acknowledge the commitment of the Government to the Arc and in particular the
status of Bedford as an area where additional growth and investment is anticipated. An example of this is the
East-West Rail line and stations.
We consider that the Council should factor in a buffer in terms of housing supply to ensure that it can meet
minimum needs, and any in addition, taking into account the need to deliver economic growth.

Object

Representation ID: 6159

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Paragraph 3.3 states that the Council will keep the Local Housing Need figure under review and will change
the figure as necessary at the time that the plan for submission is prepared. There has to be a cut-off point
for this process and for this to be explained by the Council.

Object

Representation ID: 6160

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the possibility stated at paragraph 3.5 that a stepped trajectory approach may be
appropriate for this emerging local plan.
Paragraph 60 of the NPPF, states:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a
sufficient amount and variety of land can come forward where it is needed, that the needs of groups with
specific housing requirements are addressed and that land with permission is developed without unnecessary
delay.”
Whilst we acknowledge that neither the NPPF nor the PPG specify or prescribe the method by way
development plans should seek to make provision to significantly boost the supply of new homes, paragraph
68-021 of the PPG states that proposals to use a stepped trajectory must be evidenced and not seek to
unnecessarily delay meeting identified housing needs. We consider that a stepped trajectory which might
maintain the current position of 970 dwellings per year until 2030 will not deliver on the objective to
significantly boost the supply of new homes in Bedford Borough.

Object

Representation ID: 6161

Received: 09/09/2021

Respondent: Savills

Agent: Savills

A range of emerging preferred options for the spatial strategy also known as development strategy are
provided in the consultation local plan comprising 2a to 2e. We consider the preferred strategy will to
continue with a focus on the urban area of Bedford and Kempston with additional growth that is spatially well
related to the urban rea. The definition of well related should include land adjoining and land not adjoining
the urban area but which has good connectivity potential such as walking, cycling and public transport. This
would be consistent with paragraph 73 of the NPPF.
Out of the preferred options we consider that Option 2a: Development in and around the urban area, plus
A421 transport corridor with rail based growth parishes and southern parishes, is the most sustainable and
appropriate, followed by options 2b and 2d.
We consider option 2c is least sustainable and least deliverable because of the strategic nature of some of
the locations identified. We do not of course object to the principle of new settlements but rather consider the
complexity in delivery is often underestimated in plan-making.
We do not necessarily agree with the number of dwellings included in brackets within the preferred options.
There is no explanation as to whether this is new going forward or there is an element of deduction to allow
for commitments and/or windfalls although the total figure tallies with the amount given at paragraph 3.2.
This is where more detailed explanation is necessary along with a delivery trajectory. There is no explanation
of land availability and deliverability to understand the wider context. We consider a minimum figure of 2,000
dwellings for all options for the southern parishes is an appropriate starting point.
Land at Box End, West of Bedford is capable of delivering some 1,150 dwellings being well related to the
urban area of Bedford and Kempston. The figure of 12,500 dwellings is not agreed at this stage and even if it
were to be, then this should be seen as a minimum and land identified capable of delivering more than this
minimum. This would be consistent with the NPPF paragraph 68.
Oxford-Cambridge Arc
The consultation draft provides an explanation of the Oxford-Cambridge Arc as it stood at that time.
However, since then the Government has published consultation on a vision for the emerging spatial
framework and therefore this should be taken into consideration in discussions with MHCLG and other
stakeholders.
The spatial framework for the Arc is expected to sit alongside the NPPF as national planning policy.
Therefore the assumption should be that the emerging local plan will need to be consistent with the spatial
framework, being one of the tests of soundness under paragraph 35 of the NPPF.
1.13 in the consultation local plan provides a description of the timeline for both plans and shows that the
spatial framework is likely to be published ahead of examination into the local plan.

Object

Representation ID: 6162

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the proposed sliding scale for delivery of self-build and custom build housing because
we consider this is not consistent with the NPPF paragraph 62. Under section 1 of the Self Build and Custom
Housebuilding Act 2015, local authorities are required to keep a register of those seeking to acquire serviced
plots in the area for their own self-build and custom house building. A blanket policy comprising a sliding
scale of provision such as Policy SB1 is not evidence-based and hence would not be sound. There is no
explanation as to the forecasted delivery under the sliding scale and how this might compare to evidence of
need for self-build and custom housing.

Object

Representation ID: 6163

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the proposed policy DQ1 as this is not consistent with national policy. The nationally
described space standards deals with internal space within new dwellings. It sets out requirements for the
gross internal floor area of new dwellings at a defined level of occupancy as well as floor areas and
dimensions for key parts of the home, notably bedrooms, storage and floor to ceiling height. There has to be
flexibility to this as the policy as drafted provides no flexibility. Where a need for internal space standards is
identified, local planning authorities should provide justification for requiring internal space policies. This is a
requirement under the NPPF and PPG.