Object

Representation ID: 6244

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Level of Housing Growth Required
The NPPF states that:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” (paragraph 60)
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”. (paragraph 61)
Pages 13 and 14 of the Strategy Options and Draft Policies consultation document set out the four themes reflecting the Council’s vision. The fourth theme is “Better places – Developing high quality, well-designed and beautiful places for all to use and enjoy” and includes the following objectives:
• “Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient
• Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives”.
In terms of housing growth, the current starting point for the Borough is the standard method figure, which is currently 1,275 dwellings per year, giving a total of 25,500 dwellings for the 20 year period from 2020 to 2040. The Council have also prepared a Local Housing Needs Assessment (‘LHNA’) (May 2021) (as required by paragraph 61 of the NPPF), however, this does not reflect the new affordability ratios brought out by the government on 25th March 2021 and therefore assesses local housing need against a figure of 1,305 dwellings per annum for the Borough (equating to 26,100 dwellings within the plan period). Paragraph 7.78 of the LHNA sets out that “this 26,100 consists of 15,442 additional dwellings to meet projected growth, and a further 10,658 dwellings to meet the LHN. The total should include an overlapping combination of approximately 5,000 specialist older persons households, 5,200 adapted homes and 6,400 affordable homes”. It is therefore unclear whether the decrease of 600 dwellings to the minimum requirement will have a detrimental impact on meeting this identified local need.
The Council set out that their existing commitments (planning permissions, allocations from current local plans and an allowance for windfall) equate to a total of 13,000 dwellings. The BBLP 2040 will therefore need to allocate land to provide a minimum of 12,500 new dwellings to at least meet the standard method figure. Whilst we recognise that this new annual requirement (1,275 dwellings per annum) is an increase compared to the adopted Local Plan 2030 (970 dwellings per annum), we are concerned that this does not represent an ambitious response to the aspirations of the Oxford-Cambridge Arc.
This is also reflected in the growth options, with two of the four growth options only indicating that the minimum housing and employment figures will be accommodated. Option 2d is the most ambitious and indicates that between 12,500 and 13,085 dwellings and up to 179 hectares of employment could be accommodated. The growth options also fail to consider the potential for development adjacent to alternative ‘urban areas’ (other than Bedford) such as IM Land’s Site at Land at Rushden Road, which is located within Bedford Borough but adjacent to the southern boundary of Rushden (located within the local authority area of North Northamptonshire Council) and to the western boundary of Wymington. We expand on why Rushden is a highly sustainable settlement suitable for major growth when we respond to the ‘Growth Strategy Options’ in more detail below.