1.11

Support

Representation ID: 3515

Received: 28/07/2021

Respondent: Mrs Kelly Trense

Happy to have new houses built and Bedford improved but will the sewage works be upgraded to support these extra houses? I live off Riverfield Drive and it stinks of poo at the best of times and I mean can’t open our windows or sit in our gardens stinks. So more houses will mean more poo and more stink. The Anglian Water site is also old and dated so I hope you will be pushing them to spend money on a total upgrade of it so that we don’t suffer further and so Bedford is truly modern in every way.

Object

Representation ID: 3944

Received: 29/08/2021

Respondent: Mr paul giles

bedfordshire is building a far greater number of houses than other councils, the housing burden should be spread across the country.

Object

Representation ID: 4037

Received: 30/08/2021

Respondent: Mrs Gerardine Meola

Think Government Standard needs to be reviewed. Government, local and Arc provision should not conflict

Object

Representation ID: 4049

Received: 30/08/2021

Respondent: Ann Mills

I question whether an increase of a third on the estimated housing figures for 2030 is required in Bedford Borough regardless of the anticipated economic development from the Oxford-Cambridge Arc. There are other areas I. The country that would benefit far more from this amount of additional housing.

Object

Representation ID: 4096

Received: 30/08/2021

Respondent: Debbie Irish

yet again, this assumes acquiescence. We need the BBC to think about our own people first. Other counties have pushed back on the government's assumptive over-ambitious statements and reports; BBC must do so too.

Object

Representation ID: 4321

Received: 31/08/2021

Respondent: Miss Andrea Witham

Yes, but you need to put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures. The 2014 figures are 4 years older than those of 2018, which show that far fewer homes are required.

Object

Representation ID: 4736

Received: 01/09/2021

Respondent: Mr David Rawlins

Two Local Plans are required – one based on 2014 housing figures and one based on 2018 figures. The 2014 figures are 4 years older than those of 2018, which show that far fewer homes are needed.

Object

Representation ID: 5291

Received: 03/09/2021

Respondent: Mr Stuart Ledwich

Employment is already in a stable position and we have business coming to local towns like bedford and St Neots that is not getting the support from the council they need, yet this plan seems set to push more businesses rather than supported the already established business in the area.

Object

Representation ID: 5479

Received: 06/09/2021

Respondent: Mr Stuart Ledwich

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Support

Representation ID: 5717

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

1.11 A review of business space will inform the allocation of new employment land in order to support the expansion of existing businesses and to attract inward investment. Where housing growth is concerned, as a result of existing commitments (including those made and to be made in neighbourhood plans) and new allocations to be made in this plan, Bedford Borough will make provision for significantly more homes as described in the Arc joint declaration. It will do this as a result of government's new standard method for calculating housing need which means an uplift of 33% when compared to the locally-calculated housing growth planned for in the Local Plan 2030.

Object

Representation ID: 5906

Received: 08/09/2021

Respondent: Mr Tom Tagg

Although this is an HMG issue, it must be fought:
The standard method is FLAWED and unfairly penalises Bedford. The two key components of the standard method are:
• Housing affordability:
HMG policy is that if houses are unaffordable then building more will reduce house prices. This is nonsense – house prices are driven by the market and the rate at which developers build-out. They will control the rate of build-out to maintain market price levels and their profits.
• Projection of growth: Previous growth is reviewed and projected forward – this results in a scenario where the more an area grows (and builds houses) the more it has to continue to grow (and build more houses). Bedford has grown at three times the UK average and therefore will be unfairly burdened with targets to grow even further.
The standard method needs to be revised to recognise the growth contribution areas have already made to HMG targets and to align with HMG policy to “level-up” across the UK – everywhere should take its fair share rather than overheat areas that are already growth hotspots.

Object

Representation ID: 6139

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 6975

Received: 16/09/2021

Respondent: Mr Robert Tusting

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 8278

Received: 03/09/2021

Respondent: Mr Daniel Francis

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 8330

Received: 03/09/2021

Respondent: Mrs K Francis

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 8504

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the government’s standard method provides the starting point for assessment of the number of homes to be provided through plan-making. Positive plan-making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the standard method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.
It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.
Reasoning
Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the standard method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:
- “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
- setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”
The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.
In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.
In-particular, the Council’s Employment Topic Paper:
 Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
 Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
 It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting -the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
 It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)
Remedy
Failure to take account of these factors means that the Local Plan 2040 is more likely to result in conflict with the emerging priorities of the Arc Spatial Framework and it is recommended that a range of jobs-led scenarios are tested prior to determining the housing requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 8563

Received: 03/09/2021

Respondent: Mrs Claire francis

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 8650

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

3.14 We do not object to the plan meeting LHN in full but the Council has not fully tested options to meet higher potential levels of growth as required by the NPPG (ID: 2a-015-20190220). The assessment of market signals should include expected changes in the labour market, engagement with stakeholders for economic development and changes that may affect the anticipated population and local housing stock (ID: 2a-027-20190220).

Object

Representation ID: 8703

Received: 13/09/2021

Respondent: Mr J Francis

Staploe Parish Council believe that Bedford Borough Council should put forward two Local Plans – one based on 2014 housing figures and one based on 2018 figures which provide for a much lower number of homes and argue for the former.

Object

Representation ID: 8712

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

3.16 Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the government’s standard method provides the starting point for assessment of the number of homes to be provided through plan-making. Positive plan- making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the standard method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.

3.17 It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.

Reasoning
3.18 Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the standard method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:

□ “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
□ setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”

3.19 The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.


3.20 In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.

3.21 In-particular, the Council’s Employment Topic Paper:

□ Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
□ Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
□ It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting - the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
□ It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)


Remedy
3.22 Failure to take account of these factors means that the Local Plan 2040 is more likely to result in conflict with the emerging priorities of the Arc Spatial Framework and it is recommended that a range of jobs-led scenarios are tested prior to determining the housing requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 8933

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

Paragraph 1.11 (Local Housing Need and Levels of Growth)– Comment
3.16 Meeting LHN in full should be considered to be the starting point given the pivotal point in which the Borough finds itself within the Ox-Cam Arc. The Council has demonstrably not fully tested options to meet higher potential levels of growth and there appear to be significant issues with the assumptions of labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers. As such the LP20-40 draft strategy clearly in fact fails to address the economic pillar of the NPPF2021.

Object

Representation ID: 9057

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.4. BBC explains that it plans to make provision for significantly more homes as described in the ‘Arc joint declaration’ by creating an uplift of 33% when compared with the locally-calculated housing growth planned for the Local Plan 20305. This statement by BBC requires much further clarification as it is unclear how an additional 33% is being calculated.
1.5. BBC explains that it must submit the Local Plan Review to Government to Examination by January 2023 or else the Local Plan policies will be deemed ‘out of date’. However, given the circumstances, as explained above the central purpose of requiring the quick review of the Local Plan is due to the Inspectors predicting that the details of the Arc would have been known by this time. In terms of the risk and threat of Local Plan policies being deemed ‘out of date’, recent case law has clarified the position in relation to this point and it is not as black and white as BBC has explained. We consider that this point needs much closer examination by the Council in discussion with the Secretary of State before concluding that the Local Plan must be updated ‘at all costs’ given the current local and national circumstances.