Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4996

Received: 02/09/2021

Respondent: Rainier Developments Limited (Bromham)

Agent: Marrons Planning

Representation Summary:

As the consultation acknowledges, the figure of 1,275 dwellings per year is the Local Housing Need and is the starting point. It is also the minimum number of homes needed in accordance with national policy (paragraph 61). The Council need to consider whether a higher figure is necessary in order to address the worsening issue of affordability (with average house prices 8.4 times average earnings), or in order to respond to unmet needs that may arise from neighbouring areas or from the Greater London authorities.

Full text:

As the consultation acknowledges, the figure of 1,275 dwellings per year is the Local Housing Need and is the starting point. It is also the minimum number of homes needed in accordance with national policy (paragraph 61). The Council need to consider whether a higher figure is necessary in order to address the worsening issue of affordability (with average house prices 8.4 times average earnings), or in order to respond to unmet needs that may arise from neighbouring areas or from the Greater London authorities.
However, more fundamentally, it needs to consider whether delivering the bare minimum number of homes is sufficient to match the intention for Bedford Borough to be at the heart of a national economic priority area as set out within the Oxford-Cambridge Arc Spatial Framework. In order to become one of the most prosperous, innovative and sustainable economic areas in the world, and make a major contribution to national economic recovery, the area will require labour and those people will require affordable homes unless unsustainable patterns of commuting are to prevail. The economic potential of the Arc will not be achieved, or not achieved in a sustainable way, by providing the minimum number of homes needed.
In this regard, it is questioned whether the forecast growth in jobs of 13,200 over the plan period within the LHNA (using the 2019 EEFM data) is now accurate in light of the Government’s intended strategy. The Council should review the LHNA and its anticipated job growth to assess whether there is a need to uplift the local housing need to meet the future needs of jobs and workers.
Further, the planned investment in East-West Rail, in addition to the proposed investment in sustainable infrastructure within the Arc Spatial Framework, similarly provides a strong case for a higher housing need figure than the standard method in order to satisfy the future demand that it will drive for people to live in and around Bedford. Support for a higher figure in this context is set out within the NPPG (Paragraph: 010 Reference ID: 2a-010-20201216).