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

Representation ID: 9014

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Representation Summary:

Housing Growth
4.5 Whilst the starting point of the Local Plan in determining the housing requirement for BBC is the Standard Method figure of 1,275 dpa, we can expect that BBC will required to plan for even more growth under the OxCam Arc Spatial Framework.
4.6 The live consultation for the Arc does not set out specific housing targets and therefore the individual housing targets for authorities within the Arc are currently unknown. However, based on the NIC report ‘Partnering for Prosperity’ (2017), it is likely that at least a 45% uplift is needed to help secure economic transformation across the Arc16.
4.7 BBC has acknowledged this change on the horizon (see paragraph 1.5 of the Development Strategy Topic Paper below):
“specific growth requirements and other impacts associated with the Arc are not yet known. In spite of this, councils such as Bedford are being pressed by MHCLG to continue the preparation of their Local Plans in parallel with the Arc work. The consequence of this is that the Arc spatial strategy will not be finalised in time to inform the preparation of this Plan and the Council must focus on meeting its own growth requirements as set out above”
4.8 Recognising the current lack of synchronicity in timings, changes to the NPPF since the 2040 Local Plan consultation launched means that the new visioning work will be forced to grapple with this issue. Whilst it is acknowledged that BBC cannot plan for a specific uplift figure, it is clear from the work conducted by the NIC that there will need to be a significant uplift, (notionally c 45%) that will need to take place across the Arc authorities to facilitate the level of economic growth that can potentially be achieved in the Arc. As such, it is considered that BBC should take a more proactive approach and be more forwards looking with regards to their housing need, and start to consider sites that can deliver an additional quantum of housing later on and in the post plan period which will help the Arc to achieve its sustainable growth aspirations.
4.9 A more recent example of housing requirements being increased above the Standard Method within the Arc is the consultation on the Oxfordshire Plan 2050. The Growth Needs Assessment produced in respect of this Plan (July 2021) confirms that the Standard Method figure for housing across Oxfordshire would only be 3,400 dwellings per annum. However, the GNA recognises that should Oxfordshire continue to grow economically at the levels it has been historically, a housing need of c 4,100 dpa would arise, with this increasing to c 5,100 dpa under the terms of the Growth Deal set out by the Oxfordshire Authorities in 2017.
Constraints in the Arc
4.10 Bedford is located centrally within the Arc and will be heavily influenced by the Government’s preparation of a Spatial Framework for the area. Bedford is relatively unconstrained compared to the other Arc authorities, notably Oxford and Cambridge which have seen significant levels of
housing and employment space growth and are both heavily constrained by Green Belt which might limit further expansion.
4.11 BBC also benefits from the inclusion of stations on the East West Rail line (EWR), the major role of which will facilitate links to high employment areas of Cambridge and Milton Keynes. These relative strategic advantages that Bedford enjoys would suggest that Bedford may well be considered by the Arc as a focus for additional levels of housing growth above those set by the Standard Method and TwinWoods remains a key option to achieve this.