3.1

Object

Representation ID: 5142

Received: 03/09/2021

Respondent: Mr Trevor Monk

Why must you follow? Why not form a coalition with other councils that are against it and object physically? actually stick up for your constituents?

Support

Representation ID: 5160

Received: 03/09/2021

Respondent: Mr Chris Giles

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5184

Received: 03/09/2021

Respondent: Mr Ian Francis

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which I
believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently
rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5226

Received: 03/09/2021

Respondent: Catesby Estates plc

Catesby Estates object to the intention to establish a level of housing need for the Local Plan Review linked to the standard method, with no uplift.

Object

Representation ID: 5250

Received: 03/09/2021

Respondent: Mr Peter Norris

It is impossible to accept these housing requirement figures as reasonable when for every adjacent authority area the proportion of new house targets to the areas and community sizes involved Bedford Borough had calculated significantly higher 'government targets'. This is a major inconsistency only recently highlighted by a CPRE study which requires addressing before this proposed 2040 LP can be progressed. Why are the figures so unfairly inflated for Bedford Borough and who is responsible for this?

Support

Representation ID: 5273

Received: 03/09/2021

Respondent: Mr Alan Dickinson

I appreciate the requirement for the Council to use the standard method, although I trust that representations about its flaws are made by officers and members at every opportunity.
In that context, it is wise to adopt a stepped trajectory ( see also my comments under 1)
3.9 It is disappointing that health and social care are not included here, given the ageing population
3.17 I accept that these are the best options, but new settlements should be avoided.
I believe that the reduced retail footprint in the town centre, possibly leading to a consolidation into the more central area of the offices currently on the radial roads, just outside the designated central area mean that the assumption about the potential development in the urban area is too low. And at least 2000 units should be allowed
Another opportunity offers in the semi-derelict Aspects area

Object

Representation ID: 5284

Received: 03/09/2021

Respondent: Mr Jetinder Dhaliwal

As per a previous comment, the number of homes per annum - 1,275 - is stated as per the model. The OxCam Arc requires above and beyond this number. Which is correct ?

Object

Representation ID: 5423

Received: 03/09/2021

Respondent: L&Q Estates Limited

Agent: Pegasus Group

The Council’s decision to not pursue a higher growth strategy has not been adequately justified and it fails to recognise the benefits associated with a high growth option for both housing provision and economic growth. The Council has not investigated the potential for a growth scenario that would provide a better balance between the identified socio-economic benefits and potential environmental effects. The locally assessed housing need should take proper account of significant level of job that is expected because of the Arc.

Object

Representation ID: 5495

Received: 06/09/2021

Respondent: Mr Stuart Ledwich

Staploe Parish Council believe it would be appropriate to prepare twin track local plans based on housing requirement figures calculated from 2014 and 2018 figures and argue for the use of the more up to date 2018 figures which give a lower number of homes required. The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural.

Object

Representation ID: 5530

Received: 06/09/2021

Respondent: Mr Bernard Cornwell

3.0 Emerging Preferred Options – 2a, 2b, 2c and 2d

There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in the Key Service Centres and smaller sustainable villages. None of the four emerging preferred growth options include any growth in the north of the Borough.

The north of the Borough includes several highly sustainable settlements including the Key Service Centres of Bromham, Clapham, and Sharnbrook, and the Rural Service Centres of Carlton, Harrold, Milton Ernest, Oakley, and Turvey. There are also many other sustainable villages.

The decision not to allocate further growth to the northern villages appears to be based upon the findings of the Bedford Borough Transport Model prepared by Aecom. The assessment considers a range of predetermined scenarios for growth and identifies that where a range of development is considered in the north (and across the Borough) up to 2040, there will be adverse impacts on the A6 corridor and there is no adequate mitigation available. Therefore, a broad conclusion is reached that development along the A6 corridor is constrained.

While it is acknowledged that general scenarios have to be considered in order to assess the impacts of strategic growth on the highway network, it is a very blunt tool and so its conclusions should be considered in that context. The transport modelling is clearly quite broad, particularly when considering development opportunities in the larger settlements in the north of the Borough which are primarily assessed in the “Grey scenario” (dispersed growth). In this scenario development in the north is considered as a proportion of overall growth across the Borough and the highways impact is felt more widely. This is clearly a blanket approach which lacks the fine grain of assessment necessary to properly understand the impact of growth opportunities in key locations, and therefore too easily discounts development in the Key and Rural Service Centres in the north which are sustainable settlements with capacity for growth. We would contend that the transport modelling does not provide a conclusive position that a more targeted approach to growth in the north cannot be accommodated on the highway network. The report identifies that mitigation measures are available, and therefore a more focused assessment should be considered.

Growth in the north including in the Key Service Centres, and Rural Service Centres has been too easily discounted and this is a lost opportunity as there are several highly sustainable settlements in this location. Additional growth in the northern settlements can make a positive and meaningful contribution to the wider strategy going forward to 2040, improving the long-term vitality, and the viability of existing services and facilities. We would argue that allocations should therefore be made proportionally across the Borough in the interests of long-term sustainability.

The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process, that Bromham village has embraced.

Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area

Object

Representation ID: 5537

Received: 06/09/2021

Respondent: EF Wootton and Son

There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in sustainable settlements in the north.

In setting an arbitrary distance from the edge of the urban area, the preferred strategy options remove opportunities for delivering growth in sustainable villages on the northern edge including the villages of Ravensden and Renhold. The area considered to be adjoining the urban area should also include Parishes on the edge of the urban area to ensure these settlements benefit from some growth to stop them from stagnating, and for the vitality and viability of their existing services and facilities. These Parishes present an opportunity for growth in sustainable locations within reasonable proximity of the urban area, benefiting from existing infrastructure and public transport connections. Our client would like to highlight that he has three sites at Home Farm, Ravensden Road, Renhold, (that fall within the parishes of both Ravensden and Renhold) and which would be ideal for achieving this objective. Land South of Home Farm, (Site 1467) is available for up to 50 dwellings, Land North of Home Farm (Site 657) is available for up to 30 dwellings, and Land to the Rear of Home Farm is available for up to 550 dwellings.

Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it, whilst exhibiting far fewer viability / deliverability issues. We therefore consider that sites adjoining the urban area should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area.

Support

Representation ID: 5550

Received: 06/09/2021

Respondent: Mr R Pinfold

Agent: Phillips Planning Services

3.0 Emerging Preferred Options – 2a, 2b, 2c and 2d.

Our client supports the strategies identified in Options 2a, 2b and 2d of the consultation, in which land in the southern Parishes, which includes Kempston Rural could be identified for between 750 dwellings and 2000 dwellings. It is evident from the Call for Sites Proformas that there are several sites available across these Parishes that could make a meaningful contribution towards the delivery of these strategies.

Kempston Rural is in an excellent location for growth and benefits from access straight onto the A428 link road. The Council should give full consideration to the opportunity for growth across the entire of the Parish, rather than simply limiting growth to a single strategic release.

It is further noted that the Sustainability Appraisal identifies Option 2a as the most sustainable option, and this proposes 2000 dwellings be identified in the Transport Corridor – South. If this Option, or indeed 2b or 2d, is eventually selected, our client wishes to put forward his site at Land East of Box End Road (Site 743) as a suitable site for allocation to meet this delivery.

Object

Representation ID: 5592

Received: 06/09/2021

Respondent: Mrs Julie Kilby

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5612

Received: 07/09/2021

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

In regards to housing need, currently there is no policy which identifies the housing need for the area. However,
Paragraphs 3.1, 3.2 and 3.3 identifies that based on the standard method for assessing local housing need, this provides an annual housing need figure for Bedford Borough of 1,275 dwellings per annum, giving a total of 25,500 dwellings for the 20 year period from 2020 to 2040, which is the starting point for the local plan housing requirement.
Paragraph 3.2 states that taking into account existing commitments and windfalls, the figure of 1,275 dwellings per annum will see the new local plan needing to allocation land to provide a minimum of 12,500 dwellings. It is centrally important to consider the Local Housing Need requirement in order for an appropriate and sustainable level of growth to be identified and provided for across Bedford Borough, delivering a sufficient amount of housing over the plan period. It is noted that this consultation includes a housing figure of 1,275 dwellings per annum, however, there is no real certainty within this Local Plan consultation in regards to the suitability of these figures. A key government objective is to ‘significantly boost’ housing supply, and it is felt a greater emphasis should be placed on the wording of the policy so that it is recognised as the minimum housing requirement. In fact, the figure of 1,275 dwellings per annum is less than the identified need in the Local Housing Needs Assessment, which considered that 1,305 dwellings per annum would be required. It is understood that this change has been adjusted in accordance with the recent affordability figures.
Paragraph 61 of the NPPF states that:
“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 me within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
It is important to note that Paragraph 61 of the NPPF and the associated guidance with the PPG are clear that the standard method represents the “…minimum number of homes needed…” The plan must respond to the Governments key objective of boosting the supply of housing. It is important that there is flexibility in the number of housing allocations to ensure that a five-year hosing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over-allocation housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance.
Any Local Plan currently being prepared will also have to consider the effect of the coronavirus pandemic on the housebuilding industry and subsequently, the deliverability of the Council’s current five-year housing land supply. Whilst still relatively unknown, delays in the deliverability of housing are likely, and therefore, a subsequent undersupply may occur.
The Council have calculated the annual housing need figure, based upon the Standard Methodology resulting in 1,275 dwellings per annum, or 25,500 dwellings for the period up to 2040, which is actually less than what was identified in the Local Housing Needs Assessment with the adjustment deriving from recent affordability figures. However, it is important to recognise that the need figure, when calculated using the Standard Methodology, can fluctuate year to year, based upon housing projections, and the Standard Method does not take into account economic growth. Indeed, the decrease in the housing need figure from the LHNA reflects these fluctuations. Therefore, we recommend a Housing Requirement calculated by the Standard Methodology, and a requirement which takes into account the economic growth that this plan has identified, detailed further below.
Please use a separate form (this page) for each consultation document paragraph, policy or evidence base document you are commenting on.
Which paragraph number, policy number or evidence base document are you commenting on?
Please add your comments in the box below, and continue on an additional sheet if necessary.
Just as the Local Housing Need can fluctuate, so can the buffer that is required in the context of five-year housing land supply. The Borough Council may decide to confirm their five-year housing land supply, in which case a 10% buffer would apply, and the deliverable rate may also fall over the plan period, in which case a 20% buffer would apply. We consider that a 20% buffer would ensure than the plan is future-proofed and provide flexibility, choice and competition in the housing market, reflecting government guidance. We cannot see that t his draft Local Plan 2040 nor the Local Housing Needs Assessment give any indication of the buffer the Council considers it will apply.
The draft Local Plan 2040 still relies upon Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. Since the last consultation, it is noted that six have now been formally ‘made.’ We maintain that any delays to emerging neighbourhood plans could stall the delivery of housing within the Borough. Furthermore, those which have been ‘made’ are based on the Local Plan 2030 housing need of 970 dwellings per annum. With a proposed housing need figure of 1,275 dwellings per annum in the Local Plan 2040 review, these ‘made’ neighbourhood plans are likely to require reviewing, to ensure their compliance with the new Local Plan or its review and the higher housing need. Furthermore, we maintain that Neighbourhood Plans are not subject to the same, stringent examination as Local Plans and therefore the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.
We consider that the Council should be targeting a higher housing requirement than the Local Housing Need calculated using the Standard Methodology. It is notable that the proposed requirement does not provide an uplift for economic growth. Paragraph 3.8 considers that taking into account planning population growth to 2040, 171 ha of employment land will be needed by 2040. Whilst there is a currently available supply of 48 ha, this leaves a requirement of 123 ha to be allocated in the Local Plan. Paragraph 3.9 continues to state that the Local Plan must also plan for other growth requirements that may arise, for example additional shops and services, schools and transport infrastructure. Therefore, the local plan should consider allocating land to meet purely these stated employment needs, which in turn will lead to an increase in jobs. Whilst the urban areas are likely to be the priority focus for the new local employment needs, with proposed development along the rail corridors also likely, some of this employment focus should also be towards the rural areas, helping to maintain their vitality and viability. We support the Local Plans ambition with respect to overall economic growth and believe that a housing requirement uplift is necessary to support this.
In addition, the PPG identifies other factors which need to be considered when determining the housing requirement. These include growth strategies, planning infrastructure, previous levels of delivery and recent assessments of need such as Strategic Housing Market Assessments (SHMA) where this suggests a higher need (PPG ID 2A-010) The Plan must be aspirational but deliverable to be positively prepared (NPPF, Paragraph 16), and the target of new homes per annum is insufficient to realise job-led housing need across the plan area. In order to be found sound, the Local Plan should be targeting higher growth within the Local Plan in accordance with the above explanation
In regards to spatial strategy, the previous Issues and Options consultation included six development locations/options which could form part of a strategy for growth. We responded suggesting that an amalgamation of all of the six development locations would provide a suitable strategy providing housing within the urban and rural areas. Following this consultation and the subsequent responses and other additional work around transport models, the Development Strategy Topic Paper was compiled.
The Development Strategy Topic Paper (June 2021) provides 7 options for location of growth, some of which have sub options included. These options range from development in and around the urban area only, to more dispersed development along the railway corridor and within the rural areas. From these options, emerged the preferred four options, detailed below.
The current draft Local Plan provides four emerging preferred options. All of these options seek to focus development in and around the urban area, plus along the A421 transport corridor with varying degrees of development of rail-based growth parishes, southern parishes plus the addition of one or two new settlements. Whilst the proposed four options provide a variety of figures, 1,500 dwellings are proposed to be directed to the urban area with an additional 1,500 dwellings, along with employment allocations and growth, to adjoin the urban area. All options seek to deliver at least 12,500 dwellings and up to 131 ha of employment with a minimum of
8,642 net additional jobs to be provided to 2040. It has been discussed previously how these figures should be
seen as a minimum. Whilst a larger proportion of housing and employment growth should be focused on the urban area, growth should also be located within the rural areas. In combination with the growth dispersed to the urban areas, development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. It would promote housing and would also ensure that rural areas received appropriate level of growth to maintain and enhance economic vitality, and the services and facilities required would be maintained. This approach would take account of Paragraph 79 of the Framework sufficiently to promote housing growth in the rural settlements of the Borough. In such areas, more housing would assist in maintain the vitality of the rural areas, including the retention of services and facilities that depend on economic growth. Such an approach will promote greater and more sustainable development. This is especially the case within Bedford Borough, where there may be further growth in the currently ‘rural’ areas due to the potential Oxford to Cambridge Arc.
A mix of smaller and medium scale sites can be delivered at a faster rate than the larger, allocated sites. Such sites form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow the Councils to continuously maintain a healthy and constant supply of deliverable sites.

Object

Representation ID: 5643

Received: 07/09/2021

Respondent: Mr Phillip Yockney

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Support

Representation ID: 5661

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraphs 3.1-3.7
Hallam Land Management supports the approach to the level of housing growth required, which as a “starting point” is set at 1,275 dwellings per annum and represents a significant uplift from the Local Plan 2030 requirement of 970 dwellings per annum.

Given the scale of uplift required, and significant challenges in terms of housing delivery, Hallam does not consider that a stepped trajectory would be appropriate. The example suggested in paragraph 3.5 - that the delivery target is 970 until 2030 then increased to 1,580 dwellings per annum, thereafter, equates to a significant uplift in housing delivery by 62% after 2030. It builds in the postponement of measures to meet immediate need, and it increases substantially the level of risk built into the plan since the effects of any underdelivery of stepped housing requirements on housing need would be greatly exacerbated. Hallam considers that delivery constrained to 970 dwellings in 2020-2030 would create a significant cumulative underbuild towards 2030 and is likely to undermine wider growth and planning objectives including those expected to emerge through the Oxford Cambridge Arc Spatial Framework. In this context Hallam considers that the housing trajectory is required to reflect an immediate uplift to the “starting point” of 1,275 and with a buffer. Such an approach will have implications for Spatial Strategy Options with an approach that is flexible and adaptable to change.

Object

Representation ID: 5694

Received: 07/09/2021

Respondent: Miss amber scally

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5714

Received: 07/09/2021

Respondent: Ms Sharon Rankin

Well, you are my last resort re Local Plan 2040 consultation! I’ve tried to do this online, by downloading form (which doesn’t work on my phone), just about everything I can do. You are not making it easy for people to comment, and just a thought but Bedford Borough Council website is one of the most difficult, confusing sites I’ve used, and I’m pretty tech savvy.

Anyway, I am emailing regarding local plan 2040, with very deep concerns about the amount of house building that you want to do, without putting in proper infrastructure, without consideration to the beautiful countryside we have in Bedfordshire and without care and consideration to the people who already live in the villages, hamlets, that the intended developments will be.
I live in Chawston, and today received a leaflet outlining the Denybrook development. I can’t even believe BBC are even supporting this, when TaylorWimpey will be ripping up this part of Bedfordshire for thousands of homes, just heartbreaking. Also for people that live in Great Barford, where development is also being discussed. Great Barford has already had new development, they don’t need more. At this rate, we’ll all join up and become the city of Bedford, as has happened with development in Milton Keynes, that is now swallowing up Wavendon, and Woburn Sands! We cannot allow this to happen. It’s like taking away traditional village life.

Bedford is a town, that has not been cared for, it’s town centre looks derelict, sorry, but I have family in Bedford, and they would say the same. If we need anything we go elsewhere.
Surely, if housing is required, brownfield sites should be used. I’ve heard people question as to why an area near Thurleigh is not being used for development….why?

The people of Wyboston, Chawston, Staploe, Honeydon and surrounding area do not want this development, we live here because we love our rural environment, we have been let down by BBC on every level, be it EWR and now this.
I thought I was in my forever home, but sadly not. Thousands of new homes, means thousands of vehicles on roads that will not cope, I see there is no plans for roads/infrastructure on the TaylorWimpey development, and they’re in a state now.
No, this is one bad idea. We don’t need a Wixams, look how that’s going, already people don’t have room for their cars, and as I go there regularly, I can see how bad the planning was, it’s overcrowded, and prisonlike, seems to be a common theme on new developments. Not something you’d want to put on virgin countryside. Obviously Wixams was brownfield, and was put in the right place.
We so need to look after our flora and fauna in our countryside. The more we concrete over areas, the more trees we fell, the more hedgerows we destroy, the more events like regular flooding for St Neots will happen.
Come on BBC show you can stand up for the people who live in your Borough. And why is it that the number of new homes being talked about, is so much higher than in other counties?

Object

Representation ID: 5726

Received: 07/09/2021

Respondent: Odell Parish Council

The Parish Council notes with concern and disappointment that the Borough has decided not to challenge the increase in its housing target from Central Government. The increase from just under 1,000 new homes each year to over 1,200 a year is a key determinant in the calculation of the level of new housing supply that the Borough needs to provide and suggests this is being driven by a disproportional and massive inward migration of new residents to the Borough resulting from the Oxford-Milton Keynes- Bedford- Cambridge arc. The basis of the assumptions and the associated algorithm are widely subject to considerable challenge and certainty, but has the Borough Council got the will and determination to address this essential matter?

Object

Representation ID: 5753

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

There is a query about the ONS algorithm to calculate the growth figures, so basing the housing number requirements on this needs to be challenged before the Borough set about fulfilling such housing demands.

Object

Representation ID: 5792

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which I believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. I believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5854

Received: 08/09/2021

Respondent: Mr Norman Hoy

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5929

Received: 08/09/2021

Respondent: Mr Tom Tagg

I repeat my response to 1.11:
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 continuing to grow.
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: 5975

Received: 08/09/2021

Respondent: Staploe Parish Council

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 6023

Received: 08/09/2021

Respondent: Mrs Christina Farmer

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 6112

Received: 09/09/2021

Respondent: Jen Giles

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 6167

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

Staploe Parish Council believe it would be appropriate to prepare twin track local plans based on housing requirement figures calculated from 2014 and 2018 figures and argue for the use of the more up to date 2018 figures which give a lower number of homes required. The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural.

Object

Representation ID: 6213

Received: 09/09/2021

Respondent: Peter Coles

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 6234

Received: 09/09/2021

Respondent: AW Group Limited

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 Local Plan 2030 was found sound on the basis of an average housing need
of 970 dwellings per annum (‘dpa’) across the period of 2015-2030.
2.9 The Standard Method requirement (para 3.2 of the Local Plan) meanwhile, finds
an average housing need of 1,275dpa, which the Local Plan applies across the
plan period of 2020 to 2040. There is, therefore, an overlap of some 10 years
between the two.
2.10 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.
2.11 The Standard Method has a cap which applies in instances where the strategic
policies for housing in a Local Plan have been adopted within the last 5 years1.
Whilst that is strictly correct in the case of BBC, as identified earlier in this
Statement, the spatial policies in the Local Plan 2030 effectively supressed
housing needs due to their consideration under the transitional arrangements.
2.12 There is a potential supressed need for the period 2015-2020 of some 1,550
homes (1280-970 = 310 x 5 years). It is contended, therefore, that the cap should
not apply in this instance as the spatial policies for housing need are effectively
out of date.
2.13 The Planning Practice Guidance is clear2 that the Standard Method identifies a
minimum annual housing need figure. It is not, therefore, a maximum target
and it is wholly appropriate to apply a higher housing need figure.
2.14 In this instance, whilst the housing targets for the Arc are currently unknown,
given the Plan runs until 2040, it would also be appropriate to include an uplift
to allow for additional housing to contribute to the Arc within the period.
2.15 The current strategy of deferring such a decision until the next review is not
a sound approach; it is not positively prepared planning for a spatial strategy
that will cover some 20 years. Even with a review in 5 years’ time (as is
suggested in the Local Plan), that would be close to the midpoint of the Local
Plan on the basis that this Local Plan is not likely to be adopted until 2024 (if
submission is in 2023). Moreover, the requirement is only that a Local Plan
Review is commenced in 5 years’ time, not completed, so any future review
would not be completed until after 2030.
2.16 This approach contrasts the approach taken by other authorities within the Arc,
including Oxfordshire who are currently consulting on a new Local Plan
(Oxfordshire Plan 2050) which specifically sets out that part of its purpose is to
influence and shape the emerging Arc Framework. Failure to positively plan for
the Arc now would reduce the Borough’s ability to influence the direction and
vision for the Arc through the Borough.
2.17 It is evident, therefore, that an uplift allowance in housing needs should be
included in this Local Plan to begin to accommodate future growth resulting
from the Arc. Given historic market trends and the scale of housing, an uplift of
10% (as a minimum) from the Standard Housing Method figure of 1,275dpa
would be reasonable at this time. This would lead to a new housing need of
1,403dpa (rounded). That equates to a total need of 28,050 homes across the
period 2020-2040.
2.18 In summary, therefore, the housing need figure in the Local Plan should be
increased to reflect the supressed supply in the Local Plan 2030, and future
growth from the Arc. A minimum increase of 10% should be applied, equating to
a minimum need of 28,050 homes.

Object

Representation ID: 6244

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Level of Housing Growth Required
The NPPF states that:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” (paragraph 60)
“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”. (paragraph 61)
Pages 13 and 14 of the Strategy Options and Draft Policies consultation document set out the four themes reflecting the Council’s vision. The fourth theme is “Better places – Developing high quality, well-designed and beautiful places for all to use and enjoy” and includes the following objectives:
• “Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient
• Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives”.
In terms of housing growth, the current starting point for the Borough is the standard method figure, which is currently 1,275 dwellings per year, giving a total of 25,500 dwellings for the 20 year period from 2020 to 2040. The Council have also prepared a Local Housing Needs Assessment (‘LHNA’) (May 2021) (as required by paragraph 61 of the NPPF), however, this does not reflect the new affordability ratios brought out by the government on 25th March 2021 and therefore assesses local housing need against a figure of 1,305 dwellings per annum for the Borough (equating to 26,100 dwellings within the plan period). Paragraph 7.78 of the LHNA sets out that “this 26,100 consists of 15,442 additional dwellings to meet projected growth, and a further 10,658 dwellings to meet the LHN. The total should include an overlapping combination of approximately 5,000 specialist older persons households, 5,200 adapted homes and 6,400 affordable homes”. It is therefore unclear whether the decrease of 600 dwellings to the minimum requirement will have a detrimental impact on meeting this identified local need.
The Council set out that their existing commitments (planning permissions, allocations from current local plans and an allowance for windfall) equate to a total of 13,000 dwellings. The BBLP 2040 will therefore need to allocate land to provide a minimum of 12,500 new dwellings to at least meet the standard method figure. Whilst we recognise that this new annual requirement (1,275 dwellings per annum) is an increase compared to the adopted Local Plan 2030 (970 dwellings per annum), we are concerned that this does not represent an ambitious response to the aspirations of the Oxford-Cambridge Arc.
This is also reflected in the growth options, with two of the four growth options only indicating that the minimum housing and employment figures will be accommodated. Option 2d is the most ambitious and indicates that between 12,500 and 13,085 dwellings and up to 179 hectares of employment could be accommodated. The growth options also fail to consider the potential for development adjacent to alternative ‘urban areas’ (other than Bedford) such as IM Land’s Site at Land at Rushden Road, which is located within Bedford Borough but adjacent to the southern boundary of Rushden (located within the local authority area of North Northamptonshire Council) and to the western boundary of Wymington. We expand on why Rushden is a highly sustainable settlement suitable for major growth when we respond to the ‘Growth Strategy Options’ in more detail below.