Comment

Representation ID: 9863

Received: 29/07/2022

Respondent: CPRE Bedfordshire

1. CPRE Bedfordshire believes in a democratic approach to planning and Local Plans are the cornerstone of our planning system. We commend Bedford Council’s commitment to maintaining an up to date Local Plan and the efforts they have made to open up the plan making process for the involvement of local people.
2. There are many aspects of the draft plan that we support. However, the context for the draft plan in terms of national planning policy is complex and problematic. The key objections that CPRE Bedfordshire expresses in this consultation response are very much associated with aspects of national planning policy.
3. The principal objections to Local Plan 2040 put forward by CPRE Bedfordshire relate to aspects of government policy aimed at boosting housing supply. Government ministers have stated that they are unwilling to show flexibility on the impact for Bedford of the government formula of assessing housing need (known as the Standard Method) because of concerns about delivery. However, we believe that these concerns are unjustified when Bedford Council has a record of consistently delivering or exceeding the housing requirement set in development plans in recent years.
4. Bedford Council’s strategy on housing growth is set out in the Introduction, the Vision and Objectives, and the Growth and Spatial Strategy sections of Local Plan 2040. The issues arising from this strategy give rise to our principal objections to the plan. CPRE Bedfordshire’s views on these areas are addressed collectively in in the first section of this response headed ‘Environmentally Unsustainable Housing numbers.’

Environmentally Unsustainable Housing Numbers
5. 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.
6. 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.
7. 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.
8. 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.
9. It just so happens that the higher target based on the 2014 data is in-line with the Governments Ox-Cam ambitions.
10. Regardless of the fact that we now know that Bedford Council have challenged the government’s housing delivery target for Bedford, it is a matter of great concern that an atmosphere of secrecy persists around these matters and this information has only become known due to the submission of a Freedom of Information request.
11. CPRE Bedfordshire is also very concerned to learn that Bedford Borough Council is one of six local authorities which have been meeting in private session for several years to progress the economic growth Oxford-Cambridge Arc Strategy Agenda for the area.
As far as we are aware, these meetings of the so-called Central Area Growth Board (CAGB), have never been the subject of discussion at any Bedford Borough Council Full Council Meeting which is open to the public and at which all political parties are present. Through the CAGB, discussions have been taking place with government through informal channels.
12. In May this year Hazel Simmons, council leader for Luton Borough, made an announcement that Milton Keynes Council has agreed to adopt the role of the accountable body for the Central Area Growth Board. Councillor Simmons advised that board members worked closely together last summer to develop a growth prospectus, setting out a range of regeneration and infrastructure projects for the government to invest in under its levelling up and climate change agendas. The prospectus was produced in recognition that the central area was the only one in the Ox-Cam Arc which hadn’t received a formal growth deal from the government. Apparently, this prospectus was not progressed by the Secretary of State for the Department of Levelling Up, Housing and Communities.
13. Unfortunately, to the best of our knowledge, information about the prospectus is not in the public domain and we can only speculate about its contents and ambitions.
14. CPRE Bedfordshire believes that CAGB discussions with Government are designed to achieve, “by stealth”. The hugely controversial ambition of an additional 1 million homes (20 cities the size of Cambridge) across the Ox-Cam Arc by 2050 as detailed in “The Oxford-Cambridge Arc Government Ambition and Joint Declaration between Government and Local Partners (March 2019),” to which Bedford Council are signatories, but has never published on its website.
15. CPRE Bedfordshire would like to see the following action taken:
• The Mayor and Bedford Council should be taking a far more assertive stance in discussion with government over their Local Plan 2040 Housing Target, making a stronger case for what they consider to be a sustainable housing Target i.e. between 970 and 1,000 new homes per year over the Local Plan period.
• The Mayor and Bedford Council should clarify and publish precisely what agreements/proposals have been reached by the Central Area Growth Board and government with regard to housing development.