Object

Representation ID: 8709

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

3.1 The consultation paper sets out the result of the standard method which is 1,275 new homes per
annum between 2020 and 2040 which means that after taking account of 13,000 dwellings
committed, the new local plan will need to allocate land to provide a minimum of 12,500 new
dwellings.
3.2 Paragraph 7.3 of the Sustainability Appraisal Report states a higher growth figure should be
considered of LHN plus 10%. It states:
“In considering reasonable alternatives for the amount of housing growth to be
provided in the local plan, a lower figure than 12,500 dwellings (or no growth)
is not a realistic option because of the National Planning Policy Framework
requirement for local plans to meet assessed needs in accordance with the
standard method. However this is a minimum number and a higher growth
figure should be considered for the purposes of sustainability appraisal testing.
In the absence of any methodology for calculating a higher alternative figure,
a 10% uplift to the local housing need assessment is proposed. This would give
a requirement for 1,403 dwellings per year and a total of 28,060 dwellings over
the plan period. After commitments are deducted, 15,060 dwellings would
need to be allocated.”
3.3 We endorse this need for a buffer of at least 10%, but it has not been carried forward into the
consultation paper and the options put forward. Whilst we agree that there should be a minimum
10% flexibility, we consider there should be a buffer of 20% which is based on the Local Plans
Expert Group report to the Communities Secretary and to the Minister of Housing and Planning in
March 2016. The report recommends at paragraph 11.4 that the Framework should make clear
that local plans should be required to demonstrate a five year land supply but also focus on
ensuring a more effective supply of developable land for the medium to long term, plus make
provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing
requirement, as far as is consistent with the policies set out in the Framework.
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3.4 As the plan moves forward a buffer of 20% is essential given that some of the growth is reliant on
made neighbourhood plans and from experience across the county issues arise on the timing of
delivery on allocated sites. As we set out below it would also assist with the economic aims of the
Arc and deliver much needed affordable homes in Bedford to meet a significant need.
Stepped Requirements
3.5 The Plan suggests that a stepped requirement is being considered. It states:
“Whilst more detailed work will be needed to determine this, we will consider
whether, given the significant investment in infrastructure which would be
necessary to deliver development in the borough at scale, a stepped trajectory
approach may be appropriate for this plan. This could mean, for example, that
the delivery target could be kept at 970 per year until 2030 and then increased
to 1,580 dwellings per year to make up the rest of the plan requirement over
the remaining 10 years. By 2030 the Black Cat Junction improvements will be
complete, the East West Rail section through Bedford Borough will be complete
(including new and re-modelled stations) and sufficient lead-in time will have
been available for strategic projects to be planned in detail, enabling these
higher numbers to be achieved. The forward planning will include
arrangements for new sustainable travel links, with the intention that these are
available from day one in order to embed and promote sustainable travel
choices.”
3.6 We are not against a stepped requirement given the scale of development and the timing of
infrastructure being delivered. However, we consider that the Council must consider the potential
for small and medium sized sites which are not reliant on strategic infrastructure that can deliver
early in the plan period as sustainable extensions to towns and villages rather than pursuing the
stepped requirement at this stage. If a stepped requirement is required, then it should be based
on a trajectory that factors in early delivery on small and medium sized sites and larger allocations
which so not require that new infrastructure. The imperative should be to meet the housing needs
sooner and any stepped requirement should be for new settlements only if they form part of the
strategy going forward. At this stage the presumption should be to plan for 1,275 dwellings per
annum on adoption with monitoring provisions to allow for sites to be brought forward earlier if
delivery does not keep pace with requirement. Housing completions in the recent past suggest
that delivery of 1,275 is achievable in the market with 1,350 dwellings and 1,359 dwellings being
completed in 2017-18 and 2018-19 respectively.
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Should there be an uplift of Housing Requirement?
3.7 Paragraph 61 of the Framework states:
“To determine the minimum number of homes needed, strategic policies should
be informed by a local housing need assessment, conducted using the
standard method in national planning guidance – unless exceptional
circumstances justify an alternative approach which also reflects current and
future demographic trends and market signals. In addition to the local housing
need figure, any needs that cannot be met within neighbouring areas should
also be taken into account in establishing the amount of housing to be planned
for.”
3.8 Paragraph 2a-010 of the National Planning Practice Guidance (NPPG) states:
“When might it be appropriate to plan for a higher housing need figure than the
standard method indicates?
The government is committed to ensuring that more homes are built and
supports ambitious authorities who want to plan for growth. The standard
method for assessing local housing need provides a minimum starting point in
determining the number of homes needed in an area. It does not attempt to
predict the impact that future government policies, changing economic
circumstances or other factors might have on demographic behaviour.
Therefore, there will be circumstances where it is appropriate to consider
whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much
of the overall need can be accommodated (and then translated into a
housing requirement figure for the strategic policies in the plan). Circumstances
where this may be appropriate include, but are not limited to situations where
increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities are encouraged to make
as much use as possible of previously-developed or brownfield land, and
therefore cities and urban centres, not only those subject to the cities and
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urban centres uplift may strive to plan for more home. Authorities will need to
take this into account when considering whether it is appropriate to plan for a
higher level of need than the standard model suggests.”
3.9 As set out above, the minimum local housing need figure under the standard methodology is
1,275 new homes a year for the period 2020-2040. This is a total of 25,500 homes. After taking
account of the existing commitments, the Plan seeks to make provision for 12,500 homes over the
plan period to 2040. However, there should be a critical assessment of the supply undertaken to
ensure that the Submission Plan allocates sufficient land to meet the housing requirement and
that over-estimation of existing commitment delivery does not result in under-estimation of new
allocations. That assessment should be consulted upon prior to the Submission Plan being
prepared and consulted upon.
Arc Spatial Framework
3.10 As noted in paragraph 1.8 of the consultation document, in February 2021 the Government
published a policy paper entitled ‘Planning for sustainable growth in the Oxford-Cambridge Arc:
an introduction to the spatial framework’. They are now consulting on “Creating a vision for the
Oxford-Cambridge Arc” which ends on 12th October 2021. The consultation states that its
purpose is:
“Creating a Vision for the Oxford-Cambridge Arc’, sets out the government’s
first public consultation on the Oxford-Cambridge Arc Spatial Framework. We
are seeking views to help us create a vision for the Oxford-Cambridge Arc
Spatial Framework, and in doing so guide the future growth of the area to
2050.”
3.11 A number of points arise.
3.12 Paragraph 5.5 of the Arc Spatial Framework states:
5.5 We are concerned about the affordability and availability of housing in the
Arc, and what this will mean for the Arc’s communities, economy and
environment. Development of new homes is already happening in the Arc, but
in the main centres this has not kept up with need. We also know people are
being priced out of the area, increasing the need to make more polluting
journeys for work and leisure, and making home ownership less likely for many.
And we have heard concerns about the quality and sustainability of new
development.
3.13 Paragraph 5,7 states:
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5.7 We will also seek to set policies to enable:
• new development to come forward at the scale and speed needed, in
sustainable locations, with a focus on brownfield redevelopment;
• new development to support the recovery of nature, new green space that can
be accessed by all, resilience to climate change, and protection of highly valued
existing green space; and
• housing needs to be met in full, including much-needed affordable housing.
3.14 Paragraph 5.8 states:
“5.8 In parallel to the development of the Spatial Framework, the government
is also exploring options to speed up new housing and infrastructure
development in the Arc to help meet its ambitions, where evidence supports it.
This includes examining (and where appropriate, developing) the case for new
and/or expanded settlements in the Arc, including options informed by possible
East West Rail stations between Bedford and Cambridge and growth options
at Cambridge itself. The government will undertake additional Arc
consultations on any specific proposals for such options as appropriate. The
Spatial Framework will guide the future growth of the Arc to 2050, including on
the question of new housing and infrastructure and will, as part of its
development, take into consideration any significant new housing and
infrastructure coming forward to meet the Arc‘s ambition.”
3.15 It is clear that the Arc Spatial Framework will impact on Bedford and the scale of housing. It is too
early to give significant weight to the Arc Spatial Framework but as the emerging LP2040 is being
prepared in parallel with it and “shares many of the overarching principles relating to economic
growth and the natural environment”, then planning for an additional 20% of housing not only
provides the necessary flexibility required but will also provide homes to meet the economic
ambitions of the Arc Spatial Framework.
Affordable Homes
3.16 In the case of Bedford, paragraph 5.52 of the Local Housing Needs Assessment (LHNA) states that
the affordable needs is 691 dwellings per annum which “represents a substantial proportion of
the annual growth of 771 households per annum identified by the ONS 2018-based household
projections for the LHN period 2020-2030 (10-year variant, Figure 33)”1. It represents 54% of the
standard method figure.
1 Paragraph 5.53 of the LHNA
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3.17 The Standard Method does not assess the affordable housing needs in each LPA area as the
PPG2 confirms where it states:
“An affordability adjustment is applied as household growth on its own is
insufficient as an indicator of future housing need because:
household formation is constrained to the supply of available properties –
new households cannot form if there is nowhere for them to live; and
people may want to live in an area in which they do not reside currently, for
example to be near to work, but be unable to find appropriate
accommodation that they can afford.
The affordability adjustment is applied in order to ensure that the standard
method for assessing local housing need responds to price signals and is
consistent with the policy objective of significantly boosting the supply of
homes. The specific adjustment in this guidance is set at a level to ensure that
minimum annual housing need starts to address the affordability of homes.” (our
emphasis)
3.18 Paragraph: 010 Reference ID: 2a-010-20190220 states:
“Circumstances where this may be appropriate include, but are not limited to
situations where increases in housing need are likely to exceed past trends
because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities will need to take this into
account when considering whether it is appropriate to plan for a higher level of
need than the standard model suggests.” (our emphasis)
3.19 In the case of Bedford, Step 1 of the Standard Method is 980 dwellings per annum, with Step 2
increasing it to 1,275 dwellings. The affordability uplift is therefore 295 homes, which is significantly
2 Paragraph: 006 Reference ID: 2a-006-20190220
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below the 691 affordable homes in the LHNA. This is because the affordability ratio as a long-term
adjustment to house prices which can only be seen at the end of the plan period and is not
meeting those 691 households in need per annum now and throughout the plan period.
Therefore, we consider the Council should apply an uplift to meet affordable housing needs.
3.20 To conclude, our position is that the requirement should be treated as a minimum and a flexibility
percentage should be considered and in the order of 20%. This would give a reasonable degree
of security that should sites not deliver at the rates anticipated it will:
• Help ensure there is a robust five-year housing land supply;
• deliver a greater level of affordable housing in line with the LHNA;
• deliver homes to meet the economic ambition of the Arch Spatial Framework.