Support

Representation ID: 8492

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

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 the increase (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, described as being of national importance by the Government, is delivered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, equating to 1,275 dwellings per annum, as established through the standard method. The Council consider that 13,000 dwellings will be delivered through existing commitments, derived from planning permissions, current allocations and a windfall allowance. As such 12,500 dwellings need to be planned for in the emerging Plan to ensure Local Housing Need can be met.
2.3 The Planning Practice Guidance (PPG) is clear that when establishing a housing requirement “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.” [our emphasis] (Paragraph: 010 Reference ID: 2a-010-20201216). Examples of scenarios which may justify an increase of housing requirement include growth strategies, the delivery 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. It is also important to note that Local Housing Need is, outside of the 20 largest towns and cities, a policy-off figure, as such delivering base Local Housing Need cannot be said to be delivering policy-on objectives relating to economic growth for example.
2.5 Within the emerging draft Plan 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 paragraph 1.5 of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure
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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 – ‘Creating a Vision for the Oxford-Cambridge Arc’ – 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, is entirely sensible and is 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. Even if 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 emerging 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.
2.7 It will be an unacceptable position for this emerging Plan to be subject to an early review clause, as is the case in the current Local Plan. Such an approach would merely serve to frustrate and slow much needed development.
2.8 Planning only for the baseline requirement of Local Housing Need for all Arc Authorities would result in a significant shortfall against the agreed housing target of one million dwellings up to 2050 which are needed to support the economic goals of the Arc. The Standard Method, for all authorities, totals just over 20,000 dwellings per annum. To meet the one million dwelling target across the Arc, would take around 47 years if only 20,000 homes per annum are delivered; 18 years beyond the 2050 target. Using base Local Housing Need, the Arch Authorities will deliver only 63,500 dwellings up to 2050; 65% of the housing required. It is clear therefore that planning to meet the base Local Housing Need is inappropriate and an uplift is required likely in excess of 20%. The later Authorities start to uplift their housing requirement, the harder it will be to satisfy, as fewer years will remain to deliver the need. It is therefore considered that the housing requirement should be uplifted now in accordance with the emerging Spatial Framework, as is being explored by other authorities, including West Northamptonshire which has set out that a 40% increase in housing requirement may be necessary to fulfil its housing obligations as an

Arc authority.
2.9 The proposal to utilise a stepped trajectory, referenced at paragraph 3.5 of the draft Plan, is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is primarily due to the approach to reduce the adopted Plan period, to a functional period up to 2030, despite the concerns of the development industry at the time. It is to us entirely inappropriate that these reported difficulties can be used as justification to delay current housing needs to later in the Plan period. This approach is particularly considered problematic in that, as detailed previously, housing needs will increase further; this, combined with stepping the trajectory to deliver increased numbers later in the Plan period will only further compound delivery. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites, including land east of Newton Lane, Turvey, which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised.