4.7

Object

Representation ID: 9203

Received: 25/07/2022

Respondent: Mr Tom Tagg

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

As my previous comments, BBC have followed the HMG standard method, so are compliant.

However the HMG standard method is wrong and needs revising, so that places like Bedford who have already delivered 3 times more than the national average are not forced to deliver even more development.

Object

Representation ID: 9329

Received: 28/07/2022

Respondent: Mr Eric Benton

Legally compliant? Yes

Sound? No

Duty to co-operate? No

BBC has made the point to the Government that they “are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.” The Borough should not just lie down and accept that no flexibility in the numbers can be shown

Object

Representation ID: 9424

Received: 29/07/2022

Respondent: L&Q Estates Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement figure of 12,276 across the plan period is supported but it is recommended that this housing requirement is considered as a minimum requirement to ensure flexibility in the development of the plan and to prepare for the likely uplift in housing requirement as a result of the Arc or other future long term growth ambitions of the region.

Support

Representation ID: 9604

Received: 26/07/2022

Respondent: North Northamptonshire Council

Para 4.7 of the Submission Plan states that “as a result of the government’s recent revisions to the standard method, the figure for Bedford borough currently is 1,355 dwellings per year, giving a total of 27,100 dwellings for the 20 year period from 2020 to 2040. This is the current starting point for the local plan housing requirement. Taking account of existing commitments, completions and an allowance for windfall, which amounts in total to 14,824 dwellings, this leaves 12,276 dwellings to be allocated in this plan.” The annual requirement is a 40% increase on the 970 dwellings p/a set out in the Local Plan 2030.

The increase in housing requirement was also noted in the NNC response to the Draft Plan consultation, which highlighted the importance of seeing how this would affect the Submission version of the Plan and whether this would result in any housing allocations being placed closer to the NN boundary. As stated above, no significant growth has been identified north of Bedford town that would have such an impact and the Submission Plan does not indicate a need to allocate further sites or require neighbouring authorities to take some of its growth.

It is recognised that the BBC Local Plan 2040, Plan for Submission has developed further since the Draft Plan which was consulted on last year. However, as was concluded when responding to the Draft Plan, the spatial strategy/allocated sites illustrated within the Submission Plan consultation are not considered to present North Northamptonshire Council with any significant negative implications with regards to potential cross-boundary issues. On this basis NNC has no objections to the Plan.

Comment

Representation ID: 9619

Received: 26/07/2022

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

Since there are no exceptional circumstances identified by the Council, we support the use of the standard method to calculate the housing requirement for the Borough, since this is currently prescribed method of calculating housing need. The latest calculation sees a significant 40% increase in the Boroughs housing need, rising from 970 per annum, to 1,355 per annum. In total, 27,100 dwellings are needed between 2020 to 2040.

As per our previous representations, the Local Housing Need can fluctuate year on year when calculated using the Standard Methodology. Equally, the buffer that is required in the context of five-year housing land supply can also fluctuate. We maintain that unless the Council decide to confirm their five-year housing land supply, a 20% buffer would ensure the plan is future-proofed and provides flexibility, choice and competition in the housing market, reflecting government guidance. As per previous representations, we are not clear on what consideration has been given to an appropriate buffer.

We also cannot see that an uplift has been included to take into account economic growth. The Standard Method itself does not take into account economic growth, and we, therefore, recommend a housing requirement figure, calculated by the current calculation of the time, in this case, the Standard Method, but also takes into account the economic growth. This is of particular importance when Policy DS4(S) Amount of Housing Growth seeks for the provision of 26,700 additional jobs over the plan period. We do, however, support the allocation of specific employment sites and note that Policy DM8, New employment development in the countryside, builds on Policy 7S of the Local Plan 2030 to provide a better framework for economic growth in the rural areas, helping to maintain their vitality and viability.

Despite these positive steps, we maintain that a housing requirement uplift is necessary to support the economic growth and ambition of the plan. Therefore, we currently consider that the plan is not aspirational nor positively prepared as the target of new homes per annum (especially if using a stepped trajectory discussed further below) is insufficient to realise job-led housing needs across the plan area. In order to be found sound, the Local Plan should be targeting a higher growth within the Local Plan, incorporating an economic uplift and an appropriate buffer. Indeed, the NPPG identifies other factors which need to be considered when determining the housing requirement as detailed in previous representations, all of which suggest a higher housing need should be sought.

We reiterate the key government objection to ‘significantly boost’ housing supply and maintain that greater emphasis should be placed on the wording of Policy DS3, that 27,100 dwellings over the plan period is recognised as the minimum housing required. This key objective is highlighted in Paragraph 61 of the NPPF, and the associated NPPG guidance, is clear that the standard method represents the “…minimum number of homes needed…” and the plan must respond to the Government’s key objective of boosting the supply of housing. We continue to consider that it is important that there is flexibility in the number of housing allocations to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement and consider that the Council should be seeking to over-allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance.

In regards to the stepped trajectory and Policy DS3(S), Amount and timing of housing growth, we note that for the first five years (2020/21 – 2024/25), there is no increase in the provision of the number of dwellings than the current local plan (970) requires per annum. In the next five years (2025/26 – 2029/30), there is a marginal increase of 80 dwellings per annum (1,050). The last 10 years of the plan see a significant increase in the trajectory, requiring 1,700 dwellings per annum. Whilst the principle of a stepped trajectory is acceptable, we have concerns that having a stepped trajectory that is so low in the first five and ten years of the plan period, there is a high chance that the actual housing need of 1,355 dwellings per annum is unlikely to be met as the proposed trajectory is so far below the actual requirement. In turn, this could lead to a lack of five-year housing land supply, triggering the titled balance. We suggest that a more even and achievable trajectory is considered.

Comment

Representation ID: 9883

Received: 29/07/2022

Respondent: Odell Parish Council

However, a major concern is that the Plan still uses the widely discredited Government methodology from 2014 to over-forecast the demand for new housing. This does not take account of post-pandemic changes in work-life patterns and post-Brexit reductions in economic growth. This is of great concern to current residents as it results in an excessive estimate of housing demand and hence new building sites. We would wish to see the Borough challenge these demands more rigorously in order to preserve the essentially rural nature of most of the Borough, particularly since the Borough has consistently met or exceeded its targets in recent years. In essence, we hope that Local Plan 2045v will be with us before we see 1000+ houses per year being built in the Borough.

If the main issue for the Borough is a shortage of genuinely affordable housing to rent or buy and their insufficient provision of social housing to rent through BPHA and other providers, the Plan appears to do little to address this imbalance, with major housebuilders pressing for ever more construction of expensive private housing without addressing the needs of the Borough or indeed the expanded local population. We would like to see firmer and more transparent action on this point from the Mayor and the Borough planning department.
The 500-home development proposed for our neighbouring village Sharnbrook is a case in point where the new population will increase demand on the local services that Odell residents depend on, such as the GP surgery and local schools and add to the already congested roads in both village centres and on trunk routes.

Comment

Representation ID: 10060

Received: 28/07/2022

Respondent: Great Denham Parish Council

The Parish Council discussed the draft Local Plan 2040 which has been made available for consultation at its meeting on Monday 4th July 2022, and wishes to highlight the following areas that it is unhappy with:
the high housing number for the area, particularly in the light of the recent census which shows unusually high growth in the area.

Comment

Representation ID: 10387

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

• The Government-determined Standard Method – through a variety of incorrect assumptions and processes, including its use of 2014 rather than more current data – penalises Bedford Borough as it results in a much higher housing target.

• In addition to the various actions already taken by the Council to raise concerns and object to this method, we welcome further steps to work with our parishes and Borough Councillors to oppose the Government’s methodology and their proposed planning changes.

• In a similar vein, we should write to DLUHC to request the reform of viability assessments to ensure that developers’ wider profits are taken into account and that viability includes the true cost of development including environmental standards, vital infrastructure and affordable housing.

Comment

Representation ID: 10399

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Housing Needs
2.1 Paragraph 15 of the NPPF (2021) requires Local Plans to, inter alia, provide a framework for addressing housing needs and other economic, social, and environmental priorities.
2.2 Paragraph 16 states that Local Plans should be prepared with the objective of contributing to sustainable development and be prepared positively in a manner that is aspirational as well as deliverable.
2.3 The NPPF also requires (para 23) that the Strategic Policies of the Plan should provide a clear strategy for bringing land forward to meet objectively assessed needs in line with the presumption in favour of sustainable development (para 11), and, in doing so, allocating sufficient sites to deliver the strategic priorities of the area.
2.4 National Policy therefore provides a clear, positive context with a clear requirement to meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes ambitious growth, where it is carried out in a sustainable fashion.
2.5 Bedford Borough sits in a key location within a national area of strategic importance, being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst the timetable for the Local Plan does not align with that of the Arc Spatial Framework, our client supports the approach being taken by BBC of progressing the Local Plan in advance of the Arc Spatial Framework and consider it is crucial that the Plan is adopted in a timely fashion.
2.6 The Local Plan 2030 was adopted on the basis of an early review and was examined against the 2012 NPPF under transitional arrangements. The Local Plan 2030, therefore, whilst being relatively “young” in Local Plan terms, is quite outdated in terms of its approach to housing needs. The level of growth identified and allocated in the Local Plan was based upon historic methods for identifying housing need, and, therefore, suppresses housing need for a recently adopted Plan.
2.7 The Local Plan 2040 must, therefore, address this issue in addition to considering housing needs associated with the Arc.
2.8 The Standard Method requirement (para 4.7 of the Local Plan) meanwhile, finds the Borough's housing need to be 1,355dpa, which the Local Plan applies across the plan period 2020 - 2040, creating a total of 27,100 dwellings.
2.9 The Local Plan 2030 did not, therefore, meet the housing needs as now identified based on the Standard Method. The Inspector's Report into the 2030 Local Plan recognised (IR para 40) that if the Standard Method had been applied in that instance, then the housing need figure of 1,280dpa would have applied.