Object

Representation ID: 7435

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

The DS rightly identifies the step change in housing delivery which is required in
Bedford Borough up to the horizon of the emerging plan period to 2040.
This step change results in an annual increase in housing delivery of 33% which
elevates the requirement for an annual delivery rate (within the adopted plan) of 970
additional dwellings per year to 1275 per annum for the emerging document.
It is however considered that this annualized requirement should be yet further
increased to allow for a contingency or buffer which will serve as a safety valve as
wider regional and national strategies are progressed.
A built-in contingency will allow for the LP to react to national and regional changes to
the planning system associated with Government’s agenda for planning reform and
the wider implications of the Oxford to Cambridge Arc, respectively.
The DS makes a case for the strategic target of 25,500 net additional dwellings over
the life of the plan. The document also states that current commitments are 13,000
with a balance of 12,500 dwellings to be planned for through the emerging LP – there
are concerns that the remaining requirement could be grossly under-estimated at the
point at which the LP will be adopted. As set out in the NPPG, the local housing need figure is calculated at the start of the plan-making process, but this number should be
kept under review and revised, when appropriate, until the document is submitted for
examination.
Importantly, and further to the thoughts above, the minimum local housing need figure
for the Borough may change as the LPA enter discussions with neighbouring LPAs
under the duty and as further information emerges in respect of planning reform and
the Oxford to Cambridge Arc. Whilst the evidence is not currently clear, it is
considered that ‘circumstances’ could potentially exist which would justify the adoption
of a significantly increased strategic housing target above and beyond that which is
contained within the consultation document.
Once again, it is accepted that the current position is such that the LP must
concentrate on meeting those evidenced growth requirements for the Borough and
that the plan is based on the most up to date available evidence. However, allied to
the above it is urged that the next iteration of the LP include a ‘safety valve’ which will
serve to meet any issues which arising from the aforementioned processes. The only
alternative to continued revisions to the strategic target will be yet another immediate
post-adoption review.