Object

Representation ID: 6234

Received: 09/09/2021

Respondent: AW Group Limited

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outdated in terms of its approach to housing needs.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 Local Plan 2030 was found sound on the basis of an average housing need
of 970 dwellings per annum (‘dpa’) across the period of 2015-2030.
2.9 The Standard Method requirement (para 3.2 of the Local Plan) meanwhile, finds
an average housing need of 1,275dpa, which the Local Plan applies across the
plan period of 2020 to 2040. There is, therefore, an overlap of some 10 years
between the two.
2.10 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.
2.11 The Standard Method has a cap which applies in instances where the strategic
policies for housing in a Local Plan have been adopted within the last 5 years1.
Whilst that is strictly correct in the case of BBC, as identified earlier in this
Statement, the spatial policies in the Local Plan 2030 effectively supressed
housing needs due to their consideration under the transitional arrangements.
2.12 There is a potential supressed need for the period 2015-2020 of some 1,550
homes (1280-970 = 310 x 5 years). It is contended, therefore, that the cap should
not apply in this instance as the spatial policies for housing need are effectively
out of date.
2.13 The Planning Practice Guidance is clear2 that the Standard Method identifies a
minimum annual housing need figure. It is not, therefore, a maximum target
and it is wholly appropriate to apply a higher housing need figure.
2.14 In this instance, whilst the housing targets for the Arc are currently unknown,
given the Plan runs until 2040, it would also be appropriate to include an uplift
to allow for additional housing to contribute to the Arc within the period.
2.15 The current strategy of deferring such a decision until the next review is not
a sound approach; it is not positively prepared planning for a spatial strategy
that will cover some 20 years. Even with a review in 5 years’ time (as is
suggested in the Local Plan), that would be close to the midpoint of the Local
Plan on the basis that this Local Plan is not likely to be adopted until 2024 (if
submission is in 2023). Moreover, the requirement is only that a Local Plan
Review is commenced in 5 years’ time, not completed, so any future review
would not be completed until after 2030.
2.16 This approach contrasts the approach taken by other authorities within the Arc,
including Oxfordshire who are currently consulting on a new Local Plan
(Oxfordshire Plan 2050) which specifically sets out that part of its purpose is to
influence and shape the emerging Arc Framework. Failure to positively plan for
the Arc now would reduce the Borough’s ability to influence the direction and
vision for the Arc through the Borough.
2.17 It is evident, therefore, that an uplift allowance in housing needs should be
included in this Local Plan to begin to accommodate future growth resulting
from the Arc. Given historic market trends and the scale of housing, an uplift of
10% (as a minimum) from the Standard Housing Method figure of 1,275dpa
would be reasonable at this time. This would lead to a new housing need of
1,403dpa (rounded). That equates to a total need of 28,050 homes across the
period 2020-2040.
2.18 In summary, therefore, the housing need figure in the Local Plan should be
increased to reflect the supressed supply in the Local Plan 2030, and future
growth from the Arc. A minimum increase of 10% should be applied, equating to
a minimum need of 28,050 homes.