Object

Representation ID: 9885

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

3.1 The Plan states that the result of the standard method is 1,335 new homes per annum between
2020 and 2040. The total for the plan period is 27,100 dwellings. Paragraph 4.7 states that after taking account of 14,824 dwellings committed, the new local plan will need to allocate land to provide a minimum of 12,276 new dwellings. The evidence base does not provide a critical assessment of the committed 14,824 dwellings and that will be necessary as the Plan is examined
as many may have lapsed or not be considered deliverable under the new definition in NPPF 2021.
3.2 Based on the latest affordability ratio we calculate the standard method figure to be Step 1 which is 985 dwellings per annum, with Step 2 increasing it to 1,369 dwellings.
3.3 Paragraph 7.3 of the Sustainability Appraisal Report states a higher growth figure should be considered of LHN plus 10%. It states:
“In considering reasonable alternatives for the amount of housing growth to be provided in the local plan, a lower figure than 12,276 dwellings (or no growth) is not a realistic option because of the National Planning Policy Framework requirement for local plans to meet assessed needs in accordance with the standard method. However this is a minimum number and a higher growth
figure has been considered for the purposes of sustainability appraisal testing although the Plan’s objective is to meet the Standard Methodology requirement. 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.”
3.4 We endorse a buffer of at least 10%2, but it has not been carried forward into the Plan. Whilst we agree that there should be a minimum 10% flexibility, we consider there should be a buffer of 20% which is based on the Local Plans Expert Group report to the Communities Secretary and to the Minister of Housing and Planning in March 2016. The report recommends at paragraph 11.4 that the Framework should make clear that local plans should be required to demonstrate a five year land supply but also focus on ensuring a more effective supply of developable land for the medium to long term, plus make provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework.
3.5 As the plan moves forward a buffer of 20% is essential given that some of the growth is reliant on new settlements and significant extensions, made neighbourhood plans and from experience across the county issues arise on the timing of delivery on allocated sites. As we set out below it would also assist with the economic aims of the Arc and deliver much needed affordable homes in Bedford to meet a significant need.
Stepped Requirements
3.6 Paragraphs 4.25 to 4.27 of the Plan proposes a stepped requirement. It states:
“4.25 The significant increase in the housing requirement alongside the focus on new settlements and the infrastructure delivery challenges described above
mean that housing provision across the plan period will need to be “stepped”; continuing at the same rate as it is for Local Plan 2030 for the first five years, with more significant growth post-2030 once critical infrastructure is delivered 28 and the benefits for the local economy start to be felt.
4.26 Taking account of the infrastructure delivery challenges a stepped trajectory is proposed. The following policies set out the amount and timing of
the delivery of growth to meet identified needs.
4.27 In the years up to 2030 housing supply is provided by sites allocated in Local Plan 2030 and early delivery on additional sites allocated in Local Plan 2040. After 2030, once EWR and highway improvements have been completed, the strategic growth sites allocated in this plan will be able to deliver substantial growth. Furthermore, development on some other urban sites also becomes increasingly viable. Given that the higher development rates in the second half of the plan period are primarily related to the provision of major
infrastructure and strategic sites from 2030 onwards which is required to deliver them, there will be limited scope to bring forward sites to address any shortfall which may arise in the early years of the plan.”
3.7 A number of points arise.
3.8 Firstly, the proposed phasing is not consistent with real housing needs now and there is no evidence to suggest that the need will be less in the early years of the plan. Indeed, Policy 1 (Reviewing the Local Plan 2030) states:
“The plan review will secure levels of growth that accord with government policy and any growth deals that have been agreed. The planning and delivery of strategic growth will be aligned with the delivery of planned infrastructure schemes including the A421 expressway, Black Cat junction, East West Rail link and potentially the A1 realignment.”
3.9 The evidence and the need for this early review both demonstrate the highest levels of housing need being present now, due to persistent failure to meet housing needs in previous years and a very significant backlog of affordable housing.
3.10 Figure 42 and paragraph 5.18 of the ORS LHNA states:
“Based on a detailed review of both the past trends and current estimates our analysis has concluded that 2,119 households are currently living in unsuitable housing and are unable to afford their own housing. This assessment is based on the criteria set out in the PPG and avoids double counting as far as possible.”
3.11 The affordability ratios also demonstrate an increasing affordability issue in Bedford.
GRAPH IN ATTACHMENT
3.12 Meeting this need should not be delayed further by a stepped trajectory which would reduce supply against an increasing demand with the effect of higher house prices and worsening unaffordability.
3.13 Secondly, the proposed phased approach is contrary to paragraph 60 of the Framework, which
requires the Council to support the Government’s objective of ‘significantly boosting’ the supply of homes by bringing forward a sufficient amount and variety of land where it is needed. The origins of the current Framework can be found in the previous Government’s 2017 White Paper:
Fixing our Broken Housing Market, which made it very clear that the cause for the broken market is simple: for too long, not enough homes have been built. The current Government’s ambition is to increase the supply by 300,000 new homes annually which is, as explained in the current Government’s 2020 White Paper: Planning for the Future, a figure which far exceeds the cumulative targets in adopted development plans (187,000 homes per annum) and current delivery (241,000 homes were built in 2018/19). The messages are clear: there is a national housing crisis and boosting the supply of housing now is a critical objective for the Government.
3.14 There are three stepped requirements across the plan, with the first step continuing the existing outdated requirement of 970dpa and the second step barely increasing the requirement. Most of the unmet needs are pushed to the end of the plan period. The Plan is effectively proposing that unmet needs should not just persist for a longer period, but that they will continue to
accumulate for the first 5 years of the plan which when combined with the requirement in the adopted local plan will mean some 10 years of not meet the starting point for housing need in Bedford 3 . This is wholly unacceptable and clearly contrary to the national imperative to significantly boost supply. There is no other provision within national policy or guidance which supports the use of a stepped requirement nor any evidence to suggest the housing market is not capable of delivering significant growth required. If prospective purchasers or those in need of an affordable home are not provided with a home it will exacerbate the housing crisis and/or result in out migration.
3.15 Thirdly, at the Examination the Secretary of State can have no confidence that the higher levels of delivery in later years will ever be applied as a housing requirement. Paragraph 74 of the Framework states:
“Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old.”
3.16 Therefore, when the plan is more than five years old, housing land supply will be assessed against local housing need. On this point, footnote 39 of the Framework clarifies:
“Unless these strategic policies have been reviewed and found not to require updating. Where local housing need is used as the basis for assessing whether a five year supply of specific deliverable sites exists, it should be calculated using the standard method set out in national planning guidance.”
3.17 There is therefore no guarantee that the Council will ever apply the higher stepped housing requirement. Indeed, our experience is that LPAs with a planned housing requirement that is higher than local housing need will simply not undertake a ‘footnote 39 review’ or will determine through that review that the policies do not need updating. To name a few these include East Riding, Horsham, Ribble Valley, Hinkley & Bosworth, Cheshire East, Fylde and Wyre. For Bedford, this could mean prior to the higher stepped requirement in the later part of the LP2040, the LPA may decide to not undertake a ‘footnote 39 review’ so that housing land supply is calculated under the lower standard method. In the event of allocations not delivering as expected at that point, this approach would undermine the NPPF’s objective to allow sustainable windfall sites of all sizes to be brought in to meet needs.
3.18 The fourth is that the Stepped Trajectory Topic Paper (April 2022) and the Plan states that a reason
for the stepped trajectory is that “to support the level of growth required there will be a significant infrastructure need across social, environmental and physical infrastructure. It will require significant investment in health, education and the provision of other public services, as well as green spaces to support healthy lifestyles and transport infrastructure for all modes”. This is a consequence of the chosen development strategy and an alternative would be for extensions to existing settlements which can use the existing services and facilities. There is no evidence that existing settlements do not have the capacity to support new housing. As we set out under DS5(S) those existing communities should continue to have development so that those communities can maintain or improve their sustainability and are not fossilised.
3.19 Therefore, the requirement should not be reduced in the early years of the plan period. The proposed approach is contrary to national policy, in particular paragraph 60 of the Framework, and it is not an appropriate strategy based upon the evidence base. It would compound issues of housing under-delivery at a time when the backlog of needs should be being met as urgently as possible and contrary to the reasons for this early review. Instead of phasing the requirement,
the correct approach is to boost supply in the early years of the plan.
3.20 The allocation of additional sites which are deliverable in the short term could significantly boost supply in the early years of the plan, eradicating the need to employ phasing. Insufficient consideration has been given to this potential strategy through the preparation of the plan and in particular the selection of site allocations. Such small and medium sized sites which are not reliant on strategic infrastructure that can deliver early in the plan period as sustainable extensions to towns and villages. If a stepped requirement is required, then it should be based on a trajectory that factors in early delivery on small and medium sized sites and larger allocations which so not require that new infrastructure. The imperative should be to meet the housing needs sooner and any stepped requirement should be for new settlements only if they form part of the strategy going forward. The Plan should allocate land
for at least 1,369 dwellings per annum on adoption with monitoring provisions to allow for sites to be brought forward earlier if delivery does not keep pace with requirement. With a sufficient mix of the right sites housing completions in the recent past suggest that delivery in excess of 1,335 is achievable in the market with 1,350 dwellings and 1,359 dwellings being completed in 2017-18 and 2018-19 respectively which from the AMRs were from small sites through to large sites. This shows that a mix of sites is necessary to meet the standard method. Therefore, the Council needs to employ an appropriate strategy to deliver the housing needs that have existed for the last 4 years and going forward as set out by the standard method.

Should there be an uplift of Housing Requirement?
3.21 Paragraph 61 of the Framework states:
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
3.22 Paragraph 2a-010 of the National Planning Practice Guidance (NPPG) states:
“When might it be appropriate to plan for a higher housing need figure than the standard method indicates?
The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities are encouraged to make as much use as possible of previously-developed or brownfield land, and therefore cities and urban centres, not only those subject to the cities and urban centres uplift may strive to plan for more home. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.”
3.23 As set out above, the minimum local housing need figure under the standard methodology is 1,369 new homes a year for the period 2020-2040. This is a total of 27,380 homes. After taking account of the existing commitments, the Plan seeks to make provision for 12,500 homes over the plan period to 2040. However, there should be a critical assessment of the supply undertaken to ensure that the Submission Plan allocates sufficient land to meet the housing requirement and that over-estimation of existing commitment delivery does not result in under-estimation of new allocations. That assessment has not been consulted upon prior to the Submission Plan being prepared. It will be for the Examination to critically assess the existing and new supply as a whole.
Arc Spatial Framework and East West Rail
3.24 As noted in paragraph 1.9 of the Plan, in February 2021 the Government published a policy paper entitled ‘Planning for sustainable growth in the Oxford-Cambridge Arc: an introduction to the spatial framework’. A consultation titled “Creating a vision for the Oxford-Cambridge Arc” ended on 12th October 2021. The consultation states that its purpose is:
“Creating a Vision for the Oxford-Cambridge Arc’, sets out the government’s first public consultation on the Oxford-Cambridge Arc Spatial Framework. We are seeking views to help us create a vision for the Oxford-Cambridge Arc Spatial Framework, and in doing so guide the future growth of the area to 2050.”
3.25 A number of points arise.
3.26 Paragraph 5.5 of the Arc Spatial Framework states:
5.5 We are concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.
And we have heard concerns about the quality and sustainability of new development.
3.27 Paragraph 5,7 states:
5.7 We will also seek to set policies to enable:
• new development to come forward at the scale and speed needed, in sustainable locations, with a focus on brownfield redevelopment;
• new development to support the recovery of nature, new green space that can be accessed by all, resilience to climate change, and protection of highly valued existing green space; and
• housing needs to be met in full, including much-needed affordable housing.
3.28 Paragraph 5.8 states:
“5.8 In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it.
This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself. The government will undertake additional Arc consultations on any specific proposals for such options as appropriate. The Spatial Framework will guide the future growth of the Arc to 2050, including on the question of new housing and infrastructure and will, as part of its development, take into consideration any significant new housing and infrastructure coming forward to meet the Arc‘s ambition.”
3.29 It is clear that the Arc Spatial Framework will impact on Bedford and the scale of housing. Bedford is at the heart of the Arc. Whilst it is too early to give significant weight to the Arc Spatial Framework as the emerging LP2040 is being prepared in parallel with it and “shares many of the overarching principles relating to economic growth and the natural environment”. The East West Rail is in progress and Stage 2 will extend the service from Oxford to Bedford. The full route to Cambridge is expected to be operational by 2030. This is included in the Vision (para 2.1). Given both the Arc and EWR, then planning for an additional 20% of housing not only provides the necessary flexibility required but will also provide homes to meet the economic ambitions of Bedford Borough.

Census 2021
3.30 Paragraph 8 of the ORS Report states:
"The latest official figures from the 2018-based projections show 73.1 thousand households in 2022 and suggest that this will increase to 80.6 thousand households over the period to 2032 based on the 10-year migration trend variant scenario (Fig 1); a growth of 7.5 thousand, equivalent to 10.3%”.
3.31 Figure 58 of the LNHA also uses a starting point of 71,361 households as part of the housing need assessment. However, the 2021 Census figures are now available and for Bedford the total “Number of households with at least one usual resident” at 2021 is 74,900, some 1,800 more households than predicted by the 2018 household projections. This is a materially different starting point and that underestimation should not be carried forward. Rather, the migration trends should apply to the Census figure.

Affordable Homes
3.32 In the case of Bedford, paragraph 5.52 of the Local Housing Needs Assessment (LHNA) states that the affordable needs is 691 dwellings per annum which “represents a substantial proportion of the annual growth of 771 households per annum identified by the ONS 2018-based household projections for the LHN period 2020-2030 (10-year variant, Figure 33)”4. It represents 54% of the standard method figure. This is also a clear indication as to how much of Bedford Borough’s housing growth is (and will continue to be) unaffordable.
3.33 The Standard Method does not assess the affordable housing needs in each LPA area as the PPG5 confirms where it states:
“An affordability adjustment is applied as household growth on its own is insufficient as an indicator of future housing need because:
household formation is constrained to the supply of available properties – new households cannot form if there is nowhere for them to live; and people may want to live in an area in which they do not reside currently, for example to be near to work, but be unable to find appropriate accommodation that they can afford.
The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (our
emphasis)
3.34 Paragraph: 010 Reference ID: 2a-010-20190220 states:
“Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.” (our emphasis)
3.35 In the case of Bedford, Step 1 of the Standard Method is 985 dwellings per annum, with Step 2 increasing it to 1,369 dwellings. The affordability uplift is therefore 384 homes, which is significantly below the 691 affordable homes in the LHNA. This is because the affordability ratio as a long-term adjustment to house prices which can only be seen at the end of the plan period and is not meeting those 691 households in need per annum now and throughout the plan period. Therefore, we consider the Council should apply an uplift to meet affordable housing needs.
3.36 To conclude, our position is that the requirement should be treated as a minimum and a flexibility percentage should be considered and in the order of 20%. This would give a reasonable degree of security that should sites not deliver at the rates anticipated it will:
• Help ensure there is a robust five-year housing land supply;
• deliver a greater level of affordable housing in line with the LHNA; and,
• deliver homes to meet the economic ambition of the Arch Spatial Framework.