Bedford Borough Council Local Plan 2040 Examination Stage

The Bedford Borough Council Local Plan 2040 has now reached the Examination stage. CPRE Bedfordshire have made several statements to the hearings.

Here we explain this stage of the Local Plan process and share our statements.

What is the Examination stage?

Once a Local Authority has finished preparing and consulting on a local plan it is submitted to the Secretary of State who appoints an Inspector to carry out an independent examination. This process is dealt with by the Planning Inspectorate. The examination will assess whether the plan has been prepared in accordance with legal and procedural requirements and if it is sound.

What does ‘sound’ mean?

A plan is deemed to be ‘sound’ if it is:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

How does the process work?

The Inspector considers the evidence provided by the Local Authority to support the plan and any representations which have been put forward by local people and other interested parties. At the end of the examination the Inspector will send a report to the Local Authority recommending whether or not they can adopt the plan. In most cases the report will recommend some changes that are necessary to allow the plan to be adopted. These are known as ‘main modifications’.

CPRE Bedfordshire statements

Our statement on housing targets can be read in full here: BBC LP 2040 Examination Hearings – Housing Targets (PDF)

A short summary follows below.

The question we commented on was: “Has the calculation of local housing need (27,100 dwellings across the plan period 2020-2040) been undertaken appropriately using the standard method, the correct inputs and up to date evidence?”

CPRE Bedfordshire’s position is that we are completely unable to accept the figure of 1,355 new homes per year based on a wildly exaggerated expectation of levels of inward migration. The Local Housing Need Assessment undertaken by Opinion Research Services on behalf of the Council (dated May 2021 with the April 2022 Addendum) concluded that that the housing needs of all the people of Bedford Borough over the 20 year plan period, including those people expected to migrate into the area from elsewhere in the UK, can be met by building 977 new homes p.a., a considerably lower figure than the 1,355 homes proposed in this plan, following the application of the standard method.

Water

Our statement on pressure on water supply and wastewater disposal systems can be read in full here: BBC LP 2040 Examination Hearings – Water (PDF)

A short summary follows below.

The questions we commented on were: “How have water resource issues been considered in terms of the ability to deliver the chosen spatial strategy?” and “What is the Council’s response to the representation from the Environment Agency relating to this issue?”

In our response to the ‘Local Plan 2040 Submission Version Consultation’ we highlighted our very serious concerns about the supply of drinking water and the absence of an effective and environmentally sustainable sewage system, that would be required to supply the huge housing target to be delivered over the Plan period.

Our concerns were shared by the Environment Agency which submitted objections to the Local Plan 2040 Submission Version Consultation on this issue.

This objective cannot be achieved with the massive house building target central to the Local Plan 2040 and therefore it provides yet another reason to doubt that the massive acceleration of housing growth can be delivered safely and sustainably.

South of Bedford area – housing and employment land allocations

The issue in this session was whether the housing and employment land allocations in the south of Bedford area are justified, effective and consistent with national policy. You can read our statement here – BBC LP 2040 Examination Hearings – South of Bedford area

CPRE Bedfordshire is of the view that the vision for the South of Bedford Area is not supported by appropriate evidence because the plan’s housing target is ‘excessive and unsustainable’ – terms used by the previous Mayor in correspondence with the SoS for Levelling Up when he made the case in April 2022 that the Council’s 2040 plan should be based on Locally Assessed Need and not inflated by the application of the standard method.

Further information

More information about the Examination Stage can be found on the Bedford Borough Council website.