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

Representation ID: 6475

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Representation Summary:

We agree that the Standard Method is the starting point for the Borough’s local plan housing requirement and that the eventual housing need figure will need to be informed by an updated Local Housing Needs Assessment. The allocation of land to provide a minimum of 12,500 new dwellings will also need to include additional land allocations to ensure choice and competition in the market for land and account for any fluctuations in the market. We consider this whole plan buffer should be at least 10% to meet these objectives in accordance with Paragraph 74 of the NPPF 2021. Based on the Standard Method alone, this buffer will require sufficient land allocations for 15,050 new dwellings. The application of this buffer is missing in the draft Local Plan and its absence means that appropriate levels of growth are not being fully tested and planned for in the various development strategy options. In establishing the Borough’s housing requirement, it is also important to recognise that the standard methodology represents the minimum number of homes that must be planned for. In addition, the Council will need to consider whether there are any unmet needs from neighbouring areas or whether there are scenarios that would lead to housing needs being higher than that established using the Standard Method. One such scenario is the high level of employment growth and investment being targeted in the area through the South East Midlands Strategic Economic Plan (SEMSEP) and Oxford-Cambridge Arc Economic Prospectus – both of which aim to double GVA by 2050. The government’s recent ‘Creating a vision for the Oxford-Cambridge Arc’, sets out a clear focus on making the most of the economic potential of the Arc by planning for sustainable growth to 2050 and beyond and creating a Spatial Framework that is ambitious, aspirational and unique to the Arc. To facilitate such growth the government has already invested in the East West Rail Project, connecting Oxford to Cambridge via Milton Keynes and Bedford and making it easier to connect businesses, research institutions and foster sustainable, economic growth. It is clear that housing delivery will need to keep apace with this economic growth. Will this be accounted for in the next iteration of the draft Local Plan (Regulation 19 stage) or will it will be subject to a separate strategic plan? Clarity on this essential in the interests of achieving the timetable set out in the Local Development Scheme.