The Bedford River Valley Park (BRVP) Landowners comprised of, Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (“The BRVP Landowners”) support the overall level of housing growth proposed to be delivered in the Borough over the plan period of 27,100 dwellings. This reflects Government policy and the figure required by the standard method for calculating local housing need.

The Council will need to justify its preference for a stepped trajectory when the Plan is examined in due course having regard to the guidance in the PPG at paragraph 021 Reference ID: 68-021-20190722. The BRVP Landowners would have concerns if the effect of a stepped trajectory meant that housing delivery in the first 5 years of the new plan period were limited to the lower requirement proposed for five-year land supply purposes. The housing need that the BBLP 2040 is being prepared to meet exists now. The Council has already deferred it once by making use of the transitional arrangements introduced when the 2018 NPPF was first published, meaning the BBLP 2030 was assessed against the previous version of the NPPF (2012) and its requirement for delivery of the Council’s objectively assessed need. As noted at paragraph 4.8 of the BBLP 2040, the Local Housing Need under the standard method is some 40% higher than the OAN figure in the current Plan.

It is therefore suggested that additional wording is added to Policy DS3(S) to clarify that the figure for the first 5 years of the Plan period is a minimum one and that every effort will be made to achieve the full local housing need under the standard method wherever possible.

To that end, the BRVP Landowners reiterate their commitment to work with the Council on the delivery of the BRVP Enabling Development so that the vision for the site is realised at the earliest opportunity.