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 The Local Plan 2030, therefore, whilst being relatively “young” in Local Plan terms, is quite outdated in terms of its approach to housing needs.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.