Object

Representation ID: 9857

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Local Plan is not sound (not ‘Justified’ or Effective’) in terms of the Vision because it builds in levels of housing growth which by its own admission are excessive and unsustainable.

A letter from the Council to the Secretary of State for Levelling Up Communities and Housing dated 19th April 2022 has been made available to CPRE Bedfordshire through a Freedom of Information request. In this letter the Council asks that the housing need requirement calculated through the standard method should be reviewed and revised making the case that “on the basis mainly of past over-performance, we are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.”

CPRE Bedfordshire’s published response to the Submission draft explains in paragraphs 5 to 8as follows;

Environmentally Unsustainable Housing Numbers

The Plan provides for 27,100 new homes to be delivered over the Plan period (1,355 per year). This is the highest target in the history of Bedford Council and is equivalent to building 7 new towns the size of Ampthill or 27 new villages the size of Sharnbrook. The result of this would be urbanisation on a grand scale.

CPRE Bedfordshire is aware that the Council have made representations to the government asking that the Standard Method derived targets should be revised. A copy of the Council’s letter to the Department of Levelling Up, Housing and Communities and the Minister’s reply have been obtained through a Freedom of Information request.

In their letter the Council states that following the government formula means the Council ‘are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.’ The Minister’s reply states that no flexibility can be shown because they are committed to boosting the housing supply and have concerns about delivery.

The Council say that they have no real choice other than to follow the governments expectation that local housing need will be calculated through the much criticised Standard Method formula. The government insists that outdated and inaccurate 2014 ONS (Office for National Statistics) housing formation data must be used even though more up to date and accurate figures were published by ONS in 2018. These result is a much lower housing growth target of around 1,000 new homes per year. The housing requirement that the strategy for housing growth in Local Plan 2040 is based on is, in our view, and as recognised by the Council, excessive and unsustainable. Therefore the plan is unsound on the grounds that this key aspect of the plan is unjustified.

CPRE Bedfordshire’s full response to the Submission Draft can be found at;
http://www.cprebeds.org.uk/wp-content/uploads/sites/13/2022/07/Submission-version-reponse-LP-2040-July-22-Final.pdf