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

Object

Representation ID: 6503

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

National context and plan period (paragraph 1.5)
A key point that the Council will need to address, and one that has admittedly arisen since the beginning of the consultation period, is the requirement set out at paragraph 22 of the new National Planning Policy Framework (NPPF, published 20th July 2021) which provides an expectation for local plans which encompass strategic scale development to include a vision looking ahead for the next 30 years. The new text states:
“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.”
This policy is subject to a transitional arrangement and applies only to plans that had not reached Regulation 19 (pre-submission) stage at on 20 July (or equivalent stage for Spatial Development Strategies). In which case it is applicable to the emerging Local Plan 2040. It is noted that the Government has decided against defining ‘larger-scale development’, instead concluding that this will depend on context, scale and setting and should be decided locally and tested at examination. Examples provided within the policy, however, include new settlements and large-scale extensions of existing settlements. On review of the spatial options set out at Section 3 of the consultation document this very much describes the types of development opportunities being explored by the Council.
The question which is therefore presented to the Council is whether this has any direct implications on both the plan period (currently 2020 to 2040 but plausibly should now be extended to 2050) and whether this has any additional impact on the growth targets set by the plan. Admittedly the response required by the Council is yet to be clarified in accompanying guidance (the Government’s Planning Practice Guidance is still to be updated). However, plausibly, there may now be a necessity to update the housing and jobs targets to cover an extended period beyond 2040. This could potentially increase the level of new homes to be delivered by the plan by up to 13,500 units (the current Local Housing Need figure over ten years plus a 5% uplift), although it is unclear what the repercussions on the extension of the vision would have on the objectively assessed needs to be planned for.
What is evident is that the same option no longer exists to the Council to arbitrarily shorten the plan period to address issues in respect of long-term delivery, a move taken prior to the adoption of the Local Plan 2030 and one which we maintain has now presented significant pressure on the Council to significantly increase housing delivery across the Borough in the short term (the first 5 years of the new plan period). The plan must include a positive and ambitious approach to the delivery of new homes from the very first year of the plan period to ensure a pipeline is in place to guarantee growth for the next 30 years.
What we do consider is now of critical importance in the preparation of the current plan is showing that the strategic sites to be included within it are demonstrably developable (that is there would be a reasonable prospect that they will be available and could be viably developed at the point envisaged). This issue must be met head on by the Council this time around. Indeed, the implications of paragraph 22 of the new NPPF would have resulted in a dramatically different outcome to the Local Plan 2030 which could realistically have embraced our client’s land as an allocation at that stage, a step which would have seen it delivering houses now. The problems faced in respect of the defunct Colworth village proposals aside, and despite the positive resolution of the Inspectors presiding over the examination of the Local Plan 2030, it is our view that there were (and remain) significant gaps in the evidence base surrounding how and when some of the Council’s strategic sites are to be delivered (Land South of the River and Ford End Road continue to represent sites of significant concern to our client).

Object

Representation ID: 6504

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

As part of our response to the I&O Consultation we were critical that the vision for the plan lacked ambition, particularly in light of the need to facilitate a real upwards step change in housing delivery from now onwards. At the time of the I&O document we presented the view that, as written, it could be mistaken as the vision which underpins the current Local Plan 2030, one which includes an aspirational but likely unachievable focus on housing delivery at the Borough’s town centre sites and which dodges the need to identify a wide range of immediately deliverable development opportunities on the fringes of the Bedford urban area. This view is now only amplified in light of the policy included at paragraph 22 of the new NPPF.
Too much on an onus remains in the vision on the delivery of constrained sites in the urban area and on Parish Councils to deliver growth outside of the Bedford / Kempston conurbation through neighbourhood plans. It fails to clarify that in some instances, and despite the presence of a neighbourhood plan within a parish, matters in respect of housing and employment delivery must remain squarely under the control of the Borough Council due to the critical strategic importance to deliver significant levels of growth over the plan period. As worded, we consider it presents a false expectation that rural communities are completely in control of their parish’s development strategy.
By way of an example, our client’s site represents an obvious opportunity to deliver a 400 dwelling proposal accompanied by a significant level of infrastructure at a location which will in time be covered by a neighbourhood plan (it falls within Renhold Parish). The vision must recognise that, in some instances, rural communities will be asked to welcome strategic levels of growth to contribute to the Borough’s overall housing and employment requirement, albeit this growth will bring substantial sustainability benefits to existing residents such as new schools, greater sustainable transport links and a wide variety of open space and recreational opportunities.

Object

Representation ID: 6505

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth and spatial strategy options (paragraphs 3.3 to 3.5)
Firstly, we wish to commend the Council on seeking to embrace a housing figure for the plan period which directly reflects our recommendations at I&O stage. At the point of the previous consultation the Council was equivocating over a figure somewhere within a wide range of 800 to 1,305 dwellings per annum (dpa). Following our own assessment of the appropriate housing requirement for the Borough, and on review of the likely Local Housing Need figure to be used as the start point in the calculation of the Objectively Assessed Housing Need, we recommended the following:
“The indicative range upon which the Borough’s emerging housing requirement should be based is 1,153 to 1,305 dwellings per annum. Based on a 20-year plan period until 2040 and taking into account existing commitments of approximately 11,000 dwellings this results in a revised residual requirement for the plan period of between 12,000 and 15,000 dwellings by way of new allocations.”
The Council’s current proposed annual requirement is 1,275dpa (a figure which reflects the upper end of our own suggested range) which results in a residual requirement from new allocation of a minimum of 12,500 dwelling (once again in accordance with our recommendations).
Where we do have concerns is the suggestions around the potential plan trajectory, maintaining the current delivery rate of 970dpa over the remainder of the current plan period until 2030 and only then stepping up to a requirement of 1,580 dwellings beyond this point. This would represent an abdication of the Council’s duty to boost significantly the supply of housing in the face of what is a current and urgent need for at least 1,275dpa. By way of a reminder this Local Housing Need figure is based on immediate levels of natural demand (the Office of National Statistics’ 2014-based household projections) boosted appropriately by an uplift to rectify local issues in respect of affordability. The raw ONS data alone suggests that an average of 985 new households will be created annually over the period 2020 to 2030. The maintenance of delivery of 970dpa prior to 2030 would not even meet naturally occurring demand never mind seeking to rectify issues in respect of affordability. It is imperative that as a priority the new Local Plan 2040 identifies sufficient deliverable sites that could meet the requirement for the LHN-derived 6,375 homes within the first 5 years of the plan period.

Object

Representation ID: 6506

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth and spatial strategy options (Growth strategy options paragraph 3.10)
We are pleased to note that each of the four preferred spatial options identified at paragraph 3.10 of the plan are consistent in their identification of the Bedford/Kempston urban area and its periphery as a principal location for new allocations. What is questioned, however, is why such a low number of dwellings are to be directed towards the town and the urban fringe in particular (only 1,500 of a minimum 12,500 new dwellings by way of allocation).
Firstly, on the proposed allocation of 1,500 dwellings in the urban area (that is within the existing built-up area boundary of both Bedford and Kempston) it is entirely unclear where so many deliverable or developable sites will come from. On the basis that the current Local Plan, which was only adopted 18 months ago, comprises an urban-focused approach to growth it would have been expected that in the instance that significant deliverable sites within Bedford were available at the time of its adoption they would have been identified as allocations. In which case this leads to a suggestion that the additional sites sufficient to yield a minimum of 1,500 homes have either been identified by the Council since this time or are hopefully to be identified through the call for sites process. We consider the presence of such a stock of additional reliable brownfield urban sites to be extremely doubtful, especially bearing in mind both the historic and ongoing issues faced by some of the existing town centre allocations at Ford End Road and Land South of the River in respect of land assembly, availability, and viability.
Then, in all scenarios the allocation of only 3,000 dwellings at Bedford and Kempston then leaves a minimum of 9,500 dwellings to be delivered elsewhere in a Borough with few other large and sustainable settlements. Whilst it is appreciated that each of the four strategies seek to direct these towards specific growth points or corridors it represents a significant move away from the urban focused approach taken by the Local Plan 2030. Whilst we feel that a balance must be struck – the direction of quite so many homes to Bedford’s urban sites currently is one of the main weaknesses of the Local Plan 2030 strategy – it is our clear view that there are ample opportunities on the fringe of the town that would enable growth to be delivered at the most sustainable locations in the Borough. None of the edge of the town is characterised by any restrictive landscape designations and indeed much of the local landscape character is unremarkable. In which case the delivery of unconstrained greenfield sites adjacent to the town and easily accessible to the strategic road and rail networks must present a strategic priority to the Council.
By way of an example our client’s land at Salph End represents one such strategic opportunity at a site described by our previous Call for Sites submissions as one which is entirely suitable for a new urban edge community on land which is devoid of any technical or legal constraints. The merits of the site were neatly but emphatically summarised by an Inspector presiding over a recent appeal at the land1 in respect of a proposed development for 400 dwellings and a new school site (the level and mix of development once again proposed in respect of the Call for Sites) who confirmed:
“Nevertheless, the appeal site is not without its intrinsic merits in terms of the spatial strategy; it is adjacent to the defined Settlement Policy Area of Salph End; within walking distance of a local grocery store and post office, a public transport route and some other local facilities; and it would provide that settlement with education provision and open space facilities. Most of the site was included as an allocation in a consultation version of the Local Plan before its adoption. The eventual decision to exclude the site from the plan was judged by the Inspectors who examined the plan to be a reasonable one, although they note that the matter was clearly finely balanced. It is again included in options being considered in the current review of the Local Plan and so, it is not unreasonable for the appellant’s advocate to imply, as he does in his closing remarks, that it is a matter of when, not if, the site is to be developed.”
Sites such as that of our client must be a focus and a priority in meeting what is a significant additional housing need that must be met by way of further allocations as they were upon the publication of the Council’s ‘Consultation Paper’ in 2017 (the document referred to in the Inspector’s quote above). This was prior to the more intense focus of the Council on complicated urban sites and a subsequent shortening of the plan period from 2035 to 2030 and the resultant reduction of the plan’s housing target. As such we urge the Council to significantly increase the number of homes to be directed towards the edge of Bedford within each of the four growth scenarios described in Section 3 of the draft plan with the identification of our client’s land as one of its key strategic allocations the obvious starting point.