Object

Representation ID: 6569

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Housing Requirement
2.1 The Council propose to utilise base Local Housing Need as established through the Standard
Methodology as the adopted housing requirement. The Council conclude that this uplift (from the
existing housing requirement) will assist in meeting the wider aims of the Oxford-Cambridge Arc, which
advocates for significant growth in housing to ensure economic growth in the region, which is described
as being of national importance by the Government, is not fettered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, 1,275
dwellings per annum as established through the standard method. The Council consider having regard
for existing commitments, derived from planning permissions, current allocations and a windfall
allowance which all equate to 13,000 dwellings, meaning the Council need to positively allocate 12,500
dwellings to ensure Local Housing Need can be met.
2.3 The PPG the standard method for assessing local
housing need provides a minimum starting point in determining the number of homes needed in an area
Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher
than the standard method indicates. (Paragraph: 010 Reference ID: 2a-010-20201216).
Examples of scenarios which may justify an increase of housing requirement include growth strategies,
the delivery of strategic infrastructure improvements or the requirement of an authority to take on unmet
need from a neighbouring authority.
2.4 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing
requirement from local housing need are necessary should be undertaken prior to and independently
from any consideration of the ability of an area to meet that need.
2.5 Within the draft Plan document and supporting documents, the Council do not substantively consider
any merits for uplifting Local Housing Need, beyond a brief reference to the Oxford Cambridge Arc at 1.5
of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure is a minimum.
The Council set out that it is not possible to positively plan for the increased requirements of the Arc due
to the Arc Spatial Framework having been delayed 2 years. We do not consider this to be sufficient reason to not positively Plan for this in the short term. There is currently an initial consultation on the Arc
Spatial Framework - until 12th October 2021 with a
draft Spatial Framework due to be published for consultation in autumn 2022, followed by the
implementation of a final framework.
2.6 Uplifting on the basis of the Oxford Cambridge Arc, something which is entirely sensible and in
accordance with the PPG and the Joint Declaration, signed by Bedford Borough Council. As a constituent
member of the Arc, Bedford should be involved in active engagement with the emerging Spatial
Framework and as such should be in a position to at the very least estimate the likely level of any uplift
forthcoming on the basis of ongoing discussions. The consultation document does not yet indicate a
specific locations and levels for growth, however great emphasis is placed on the concern about the
economy and environment. Place-making will be at the heart of the Arc utilising the opportunity for it to
a world leader in sustainable place-making and community living
2.7 Even if in due course there is some debate as to the level of update required, the Council could choose a
conservative uplift in the interim period. For example, if the level of uplift in the draft document is
proposed to be 30%, the Council could seek to positively apply an uplift of 20% as part of this Plan. This
is positive, in keeping with the Framework and entirely sensible. A more positive approach at this stage
will enable the Council to better Plan strategically for future uplifts, through for example through the
delivery of strategic sites.
2.8 It will be an unacceptable position for this Plan to again by caveated by an early review clause, as was
the Case in the current Local Plan. This will merely serve to frustrate and slow much needed
development.
2.9 It is evident running base Local Housing Need of all Arc Authorities would result in a significant shortfall
against the agreed housing target of a million dwellings up to 2050 which are needed to support the
economic goals of the Arc. In total, the result of the Standard Method for all authorities is just over 20,000
dwellings per annum. This means it will take around 47 years to reach the housing target, if all authorities
simply make provision for base Local Housing Need, 18 years beyond the 2050 target. Using base Local
Housing Need, the area will deliver only circa 63,500 dwellings up to 2050, only around 65% of the
housing required. It is therefore demonstrable at this stage that base Local Housing Need is
inappropriate, and an uplift is required likely in excess of 20%. The later Authorities begin to uplift their
housing requirement, the harder it will be to satisfy, as fewer years will remain. We therefore consider that the Council should seek to uplift the housing requirement now in accordance with the emerging
Spatial Framework, as is being proposed by other authorities.