Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9584

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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 The Local Plan 2030, therefore, whilst being relatively “young” in Local Plan terms, is quite outdated in terms of its approach to housing needs.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 of 2020 to 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.
2.10 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.
2.13 In particular, the Sustainability Appraisal testing of the ‘stepped approach’ is fundamentally flawed, with the justifications given for positive scores around items such
as previously developed land (see SA Appendix 8 p. 113) being conjecture. The statement that the stepped approach would have a more beneficial effect on
development on previously developed land is incorrect; sites which are previously developed land can come forward irrespective of the stepped approach and the SA does not identify any previously developed land south of Bedford that benefits from the new rail stations and links. Indeed, the allocations at locations such as the Wixams are not on previously developed land but greenfield land. The SA must, therefore, be re-run with a correct assessment of the stepped approach.
2.14 A correct assessment of the stepped approach in the SA would identify that there are risks with being reliant upon so much growth linked to strategic infrastructure outside of the control of developers and the Council. This would in turn mean that many of the
benefits may not be realised, or realised later in the plan period, pushing housing delivery outside of the plan period.
2.15 This is particularly evident in this area, with the still awaited deliver of the Wixams rail station. That station was due to be completed in 2015 and is now timetabled for opening in 2024.
2.16 Instead, the Plan should take a more balanced approach, with a reduction in numbers on some of the strategic sites and the delivery of smaller strategic allocations which can come forward earlier and increase housing delivery in the period to 2030.
2.17 The Local Plan is not sound, as it is not justified or effective. To make the Plan sound the trajectory should be amended. Reflecting the fact that the Local Plan may not be adopted until 2023, and thus higher delivery in 2024 (compared to the Local Plan 2030), the trajectory should be as follows:
2020/21- 2023/24: 970dpa
2024/25 – 2039/40: 1,423dpa
2.18 Aligned with this, new allocations will be required, and a reduction in the number of dwellings on some strategic sites may be required.

Object

Representation ID: 9586

Received: 29/07/2022

Respondent: Arrow Planning Limited

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 XX 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.

Object

Representation ID: 9587

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

3.1 The spatial strategy of focusing growth in the south of Bedford area (Policy HOU12) is supported by our client. However, our client contends that the approach taken to
allocating sites and, in particular, the quantum of development allocated on certain sites is not justified nor consistent with national policy, for the following reasons.
3.2 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13, HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear understanding and expectation as to the quantum of development that the Plan is proposing in these locations.
3.3 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
3.4 What is not evident from the evidence base or the Local Plan, is the approximate developable areas and thus whether these are realistic densities. Upon examination of the Policies for each site, and the Figures in the Local Plan which accompany each, the only way to achieve all the Policy requirements, in particular the amount of open space and green infrastructure, would necessitate very high densities on the majority of these
sites (c. 50/60+ dph).
3.5 There is no evidence accompanying the Local Plan which justifies this approach; the HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which a high density would lead to, nor is there market evidence supporting housing demand for such a high quantum of small units in these locations.
3.6 This is likely to lead to future applications which either decrease the number of homes, resulting in unmet need (in terms of overall quantum and/or mix) and possibly nondelivery of key infrastructure. Alternatively, it may lead to non-delivery of green infrastructure due to pressures to deliver housing numbers.
3.7 The quantum for each allocation is not based on a proportionate or robust evidence base and are therefore not sound.