Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9876

Received: 28/07/2022

Respondent: Taylor Wimpey

Representation Summary:

In terms of the amount of housing, we have a concern that the Council are relying on the standard method housing figure as the housing requirement without considering in more detail if a higher target would be appropriate.
The PPG at several points, including paragraph 10 (reference ID: 2a-010-20201216) is clear that the standard method provides the minimum starting point for determining how many homes are needed in an area – it does not set the requirement. It lists a number of circumstances where housing need in the future may be higher than the standard method indicates, including where there are strategic infrastructure improvements that are likely to drive an increase in the demand for homes. This is the exact situation in Bedford with East West Rail and the highway improvements to the east of Bedford, which will massively improve access to Cambridge.
The Sustainability Appraisal does briefly consider alternative numbers, immediately ruling out a lower number. When discussing a higher alternative housing figure it states: ‘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 29,810 dwellings over the plan period. After commitments are deducted, 14,986 dwellings would need to be allocated.’
This matter is then revisited at Section 9.2 of the Sustainability Appraisal where it briefly states that the Council have adopted the Government’s Standard Methodology housing figure. The decision not to use a higher alternative housing requirement is justified on that basis that:
“A higher level of growth that exceeds housing needs would result in a number of negative effects on sustainability appraisal objectives which exceed the benefit of the identified positive effects. Such higher growth is not a reasonable option. It would not be deliverable and would not be supported by the Council because of the lack of evidence to show that a higher level of growth is required and the perceived negative effects on existing communities and the environment. A growth option which meets the assessed housing need for growth (including a buffer) is the only reasonable option.”
We contend that this is insufficient analysis to consider if a higher requirement could be appropriate and that this needs to be revisited for the Plan to be sound.
The use of a stepped trajectory as proposed is consistent with the National Planning Practice Guidance (reference ID: 68-021-20190722). However, this should only be on the basis on the relationship with planned infrastructure and should not unduly delay the delivery of housing to meet local needs, as is made clear in the PPG.
We have a concern that the stepped approach set out in DS3 will conflict with this requirement by unnecessarily delaying the delivery of homes. As is set out in our comments on policy DS5 below, to rely solely on existing commitments in the rural area and villages is a fundamental error of the plan is it negates the important contribution the small and medium sized sites in the larger villages can make to meeting short term housing need without a need for significant infrastructure investment. Therefore, whilst we agree that a stepped trajectory may be capable of being justified in the Plan, the way it is currently drafted is unsound as it unnecessarily delays the delivery of housing.