Object

Representation ID: 6372

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 3.1 to 3.5 – OBJECT
Calculation of Bedford’s housing requirement

The current Local Plan 2030 requires that the Council arrange for the development of 970 new homes per year over the Plan period. The proposed new Local Plan 2040 will increase this by 32% to 1,275 new homes per year over the 20 year period of the Plan – a total of 25,500 new homes.

The calculated housing requirement of 25,500 dwellings is equivalent to building around 25 new villages the size of Sharnbrook (approx. 1,000 homes) or six new towns the size of Ampthill (approx. 4,000 homes).

Existing commitments
A full breakdown of existing commitments, referred to as representing 13,000 dwellings (including allocations from current local plans and an allowance for windfall) should be provided so that the accuracy and reasonableness of this figure can be examined. In the absence of an analysis of the forward trajectory upon which this figure is based, the gap between the proposed housing requirement figure and existing commitments cannot be verified.

Key Rural Service Centres
In regard to the allocations from current local plans, CPRE Bedfordshire believe that the substantial inflation of the housing requirement in the 2030 plan as well as this draft 2040 plan has resulted in excessive expectations upon the Key Service Centres of Bromham, Clapham, Great Barford and Sharnbrook. The Council should be challenging the current government advice on the standard method so that the Council’s housing requirement can be recalculated based on the most up to date data from the Office for National Statistics (ONS). This would allow for the current expectations for new housing delivery from the Key Service Centres, currently totaling 2,000 homes, to be reduced by at least 50%.

CPRE Bedfordshire fully recognises the need for new homes for the people of Bedford
Borough and in particular, affordable homes and social housing. However, these huge
numbers are based on inaccurate and outdated 2014 housing data from ONS and the much criticised Standard Method algorithm which the government insist that local authorities use to determine housing need. This is despite considerable disquiet among government MPs and demographic experts, including the highly regarded company Opinion Research Services (ORS), which was responsible for preparing the Council’s Local Housing Need Assessment upon which the draft Local Plan 2040 is based.

ORS point out in the “Bedford Borough Housing Needs Assessment” (HNA) page 12, para 28, that the housing needs of all the people of Bedford Borough over the 20 year Plan period, including those people expected to migrate into the area from elsewhere in the UK, can be met by building 15,442 new homes, a very considerable reduction on 25,500 proposed in the Local Plan.

The government then insist however, that a further 8,877 new homes are added to the
15,442 to encourage even more inward migration into the Borough.

As ORS point out in a comment on page 74 of the HNA para, 6.16:
“This level of inward migration is notable ……… The extra 8,877 dwellings for inward
migration implied by the standard method represents an increase of 88% over and above
the inward migration already included in the most up to date household projection” i.e.
15,442 new homes.

This is a staggering increase with no justification from Government.

The ORS data shows that approximately 70% of the total of 25,500 new homes to be built in
the Plan period are to encourage a massive inward migration of people from elsewhere in
the UK to Bedford Borough.

This is a key part of the Government’s development plans for the OxCam Arc which the Mayor and the Council have signed up to without consulting local people.

These plans will not make housing cheaper or any more accessible for local people – driving
a huge inward migration of people into Bedford Borough will simply increase housing
demand and therefore increase the price of new homes and building land. The only people
to benefit from this will be developers and landowners/speculators.

If accurate, up to date ONS data is used from 2018 Housing Formation analysis, then the calculated housing need for the Borough would be similar to the current Local Plan 2030 housing requirement of 970 dwellings per annum.

CPRE Bedfordshire's position is that we are completely unable to accept the figure of 1,275
new homes per year which will destroy the Bedfordshire countryside at a time of:
• Climate Emergency
• Catastrophe of biodiversity loss - bird species in the UK have dropped by between 40% and 70% in the last 40 years and insect populations by similar numbers and the decline is increasing at pace.
• The UK’s ranking amongst the most nature depleted nations on earth.

The cause of much of this has been the "Growth At Any Cost Agenda" that has been
followed for many years. We urge the Council to reject this agenda and the "business as
usual" approach and to look towards different, more modern and more environmentally
sustainable objectives.

This means turning away from the government’s OxCam housing growth ambitions and
focus on building good quality affordable housing for local people (including a reasonable level of inward migration) and the protection and enhancement of the beautiful Bedfordshire countryside, not its destruction.

Bedfordshire is one of the smallest counties in England but the 13th most densely
Populated. Our countryside is therefore precious.

Comparisons with other Local Planning Authority housing targets

CPRE Bedfordshire has compared Bedford Council’s housing target, which has been calculated using the government’s discredited standard method algorithm, to the housing targets of other surrounding local authorities.

In this comparison, Bedford Council’s housing target of 1,275 new homes per year for the next 20-year duration of its draft Local Plan 2040 is shown to be:
• One of the highest of any local authority in the southeast of England outside of the Greater London Metropolitan area.
• Higher than that of the city of Cambridge or any local authority in Cambridgeshire.
• Higher than the housing target of the city of Oxford or any local authority in the county of Oxfordshire – in fact, it is almost double the target of each local authority in Oxfordshire
• Bedford Council’s housing target is over 30% higher than that of Huntingdonshire District Council, part of Cambridgeshire, and 18% higher than that of South Cambridgeshire Council. (Both of these Cambridgeshire authorities have similar
populations to that of Bedford Borough.)

The counties of Oxfordshire and Cambridgeshire are more than twice the size of Bedfordshire, which is one of the smallest counties in England.

Bedford Council’s housing target is 31% higher than that of North Hertfordshire, 180% higher than East Northamptonshire, 142% higher than Kettering and 266% higher than Wellingborough.

Detailed comparisons are shown in the appendix.