Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10399

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Housing Needs
2.1 Paragraph 15 of the NPPF (2021) requires Local Plans to, inter alia, provide a framework for addressing housing needs and other economic, social, and environmental priorities.
2.2 Paragraph 16 states that Local Plans should be prepared with the objective of contributing to sustainable development and be prepared positively in a manner that is aspirational as well as deliverable.
2.3 The NPPF also requires (para 23) that the Strategic Policies of the Plan should provide a clear strategy for bringing land forward to meet objectively assessed needs in line with the presumption in favour of sustainable development (para 11), and, in doing so, allocating sufficient sites to deliver the strategic priorities of the area.
2.4 National Policy therefore provides a clear, positive context with a clear requirement to meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes ambitious growth, where it is carried out in a sustainable fashion.
2.5 Bedford Borough sits in a key location within a national area of strategic importance, being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst the timetable for the Local Plan does not align with that of the Arc Spatial Framework, our client supports the approach being taken by BBC of progressing the Local Plan in advance of the Arc Spatial Framework and consider it is crucial that the Plan is adopted in a timely fashion.
2.6 The Local Plan 2030 was adopted on the basis of an early review and was examined against the 2012 NPPF under transitional arrangements. The Local Plan 2030, therefore, whilst being relatively “young” in Local Plan terms, is quite outdated in terms of its approach to housing needs. The level of growth identified and allocated in the Local Plan was based upon historic methods for identifying housing need, and, therefore, suppresses housing need for a recently adopted Plan.
2.7 The Local Plan 2040 must, therefore, address this issue in addition to considering housing needs associated with the Arc.
2.8 The Standard Method requirement (para 4.7 of the Local Plan) meanwhile, finds the Borough's housing need to be 1,355dpa, which the Local Plan applies across the plan period 2020 - 2040, creating a total of 27,100 dwellings.
2.9 The Local Plan 2030 did not, therefore, meet the housing needs as now identified based on the Standard Method. The Inspector's Report into the 2030 Local Plan recognised (IR para 40) that if the Standard Method had been applied in that instance, then the housing need figure of 1,280dpa would have applied.

Object

Representation ID: 10400

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Local Plan then proposes a stepped trajectory approach to deal with housing need, with only 970 homes per annum in 2020-2025, and 1,050 between 2025-2030. There would then be a significant increase to 1,700dpa in the final 10 years of the Plan.
2.11 The justification for this approach is due to the over reliance upon strategic allocations which large infrastructure requirements.
This is not considered a sound approach and is effectively putting all the Council’s ‘eggs in one basket’. It is not justified by the evidence and the Local Plan.

Object

Representation ID: 10402

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Plan Period
2.19 Turning to the matter of Plan length, Mr R S contends that the Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change.
2.20 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for.
2.21 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas. The next review of the Local Plan would then not need to extend the Plan Period, but instead revise housing and employment growth to reflect the latest position as relevant at that time.