Bedford Borough Local Plan 2040 Plan for Submission

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Object

Bedford Borough Local Plan 2040 Plan for Submission

Policy DS2(S) Spatial strategy

Representation ID: 10008

Received: 27/07/2022

Respondent: North Hertfordshire District Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We are currently anticipating the adoption of our own Local Plan for the period 2011-203. Once complete (and without prejudice to any Inspector’s report or decision on adoption), this would – along with the Plans for neighbouring Luton and Central Bedfordshire – complete the statutory planning framework for addressing the housing needs of Luton over this period.
It is our understanding that Luton intend to commence a review of their own Local Plan once the issue of its housing needs over the period 2011-2031 have been fully resolved. Key decisions around that Plan are yet to be made, in terms of plan period, housing requirements, potential development capacity within Luton etc. Proposed Government reforms to the planning system are also anticipated. These may include successor arrangements to the current statutory Duty to Co-operate. However, I would presently anticipate that unmet development needs from Luton for the period beyond 2031 could well be an issue that requires further consideration in this next round of plans.
Under the agreements reached for the current round of plan-making it was acknowledged that, in the first instance, authorities within the functional Luton Housing Market Area (Luton, Central Bedfordshire, North Hertfordshire and Aylesbury Vale) would work together to meet any unmet needs to the best of their abilities. In the event unmet needs arising from Luton could not be met within the defined Luton Housing Market Area, it would be necessary to initiate a wider search within adjoining housing market areas with good links to the town.
It has been acknowledged by the authorities in the housing market area that North Hertfordshire has made the maximum reasonable contribution to unmet housing needs from Luton in its current Plan. Central Bedfordshire have faced significant challenges in accommodating unmet needs from Luton alongside their own needs that arise within areas of the authority that fall within the Luton Housing Market Area. However, between the two authorities, it is proposed that the identified unmet needs of Luton for the period to 2031 will be met.
Your current consultation fails to identify and acknowledge the good strategic connections that it benefits from in relation to Luton, as discussed in our previous response letter to your Reg 18 consultation where paragraph 6.2 (of that document) identified:
Bedford benefits from good strategic connections to London and nearby economic centres, such as Milton Keynes and Luton, and planned improvements to connect to Cambridge.
Policies DS2(S): Spatial Strategy, and DS3(S): Amount and timing of housing growth, fail to acknowledge the role that Bedford Borough plays in the wider Housing Market Area and the contribution that it can make to neighbouring authorities housing need, such as Luton. As such, we find the policies unsound due to the lack of regard for neighbouring authorities’ housing requirements.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Policy DS3(S) Amount and timing of housing growth

Representation ID: 10009

Received: 27/07/2022

Respondent: North Hertfordshire District Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We are currently anticipating the adoption of our own Local Plan for the period 2011-203. Once complete (and without prejudice to any Inspector’s report or decision on adoption), this would – along with the Plans for neighbouring Luton and Central Bedfordshire – complete the statutory planning framework for addressing the housing needs of Luton over this period.
It is our understanding that Luton intend to commence a review of their own Local Plan once the issue of its housing needs over the period 2011-2031 have been fully resolved. Key decisions around that Plan are yet to be made, in terms of plan period, housing requirements, potential development capacity within Luton etc. Proposed Government reforms to the planning system are also anticipated. These may include successor arrangements to the current statutory Duty to Co-operate. However, I would presently anticipate that unmet development needs from Luton for the period beyond 2031 could well be an issue that requires further consideration in this next round of plans.
Under the agreements reached for the current round of plan-making it was acknowledged that, in the first instance, authorities within the functional Luton Housing Market Area (Luton, Central Bedfordshire, North Hertfordshire and Aylesbury Vale) would work together to meet any unmet needs to the best of their abilities. In the event unmet needs arising from Luton could not be met within the defined Luton Housing Market Area, it would be necessary to initiate a wider search within adjoining housing market areas with good links to the town.
It has been acknowledged by the authorities in the housing market area that North Hertfordshire has made the maximum reasonable contribution to unmet housing needs from Luton in its current Plan. Central Bedfordshire have faced significant challenges in accommodating unmet needs from Luton alongside their own needs that arise within areas of the authority that fall within the Luton Housing Market Area. However, between the two authorities, it is proposed that the identified unmet needs of Luton for the period to 2031 will be met.
Your current consultation fails to identify and acknowledge the good strategic connections that it benefits from in relation to Luton, as discussed in our previous response letter to your Reg 18 consultation where paragraph 6.2 (of that document) identified:
Bedford benefits from good strategic connections to London and nearby economic centres, such as Milton Keynes and Luton, and planned improvements to connect to Cambridge.
Policies DS2(S): Spatial Strategy, and DS3(S): Amount and timing of housing growth, fail to acknowledge the role that Bedford Borough plays in the wider Housing Market Area and the contribution that it can make to neighbouring authorities housing need, such as Luton. As such, we find the policies unsound due to the lack of regard for neighbouring authorities’ housing requirements.

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