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

Representation ID: 6158

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Representation Summary:

Growth and Spatial Strategy
Paragraph 3.1 in the consultation local plan, states:
“Government guidance sets out a standard method for calculating future housing requirements, which the
Council must follow. As a result of the government’s recent revisions to the standard method, the figure for
Bedford borough currently is 1,275 dwellings per year, giving a total of 25,500 dwellings for the 20 year
period from 2020 to 2040. This is the current starting point for the local plan housing requirement.”
Paragraph 3.2 goes on to state that the new local plan will need to allocate land to provide a minimum of
12,500 new dwellings. This follows deductions for existing commitments and a windfall allowance. The
minimum 12,500 dwellings represents just under 10 years of supply under the minimum local housing need.
This is not soundly based because it does not follow publication of a review of existing commitments to know
whether these new homes will be delivered as envisaged. There is no delivery trajectory or forecast included
within the consultation version of the local plan and there should be.
The December 2020 Indicative Housing Need for Bedford Borough published by the Government identified a
figure of 1,305 dwellings per year. As the Planning Practice Guidance states at 2a-010 this is just the starting
point which is often described as the minimum. There needs to be an explanation of what options the
Council has looked at and discounted for whatever reason within the consultation document. The Council will
need to explain whether there is sufficient housing being proposed to support future economic growth,
especially given the location within the Oxford-Cambridge Arc. We acknowledge that the new local plan and
the spatial framework are not entirely aligned in terms of timescales but nonetheless it is important for the
emerging new local plan to acknowledge the commitment of the Government to the Arc and in particular the
status of Bedford as an area where additional growth and investment is anticipated. An example of this is the
East-West Rail line and stations.
We consider that the Council should factor in a buffer in terms of housing supply to ensure that it can meet
minimum needs, and any in addition, taking into account the need to deliver economic growth.