3.1

Object

Representation ID: 6314

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

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: 6356

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

The standard method figure for Bedford Borough is set out in Chapter 3 of the consultation document at 1,275 dwellings per year (25,500 dwellings in total). With existing commitments taken into account, the plan will therefore need to allocate land to provide a minimum on 12,500 new dwellings.
However, it has not been made clear in what has been published whether the existing commitments that have been identified include the emerging Neighbourhood Plan allocations
(which are intended to satisfy the requirements of adopted Local Plan policy 4S). Should these be taken into account as commitments, the minimum level of growth that will need to be delivered in the Local Plan may need to increase should any of the emerging Neighbourhood Plans fail to come forward, fail at examination or not pass referendum.
It should also be stressed that the 25,500 housing requirement identified as part of the standard methodology is the minimum number of homes that need to be delivered over the plan period for the Bedford Local Plan 2040. There will need to be an additional allowance made in the allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays in order to ensure that this figure is delivered.
It is common practice to make an additional allowance of 10%, equating to land for 2,550 homes over the minimum, in order to ensure that there is an appropriate contingency in place for under delivery. At paragraph 1.50 of the published Draft Strategy Options Document there is reference to ‘choice and flexibility’, however this comment is only made in relation to the potential additional growth that could come forward via neighbourhood plans. As a result of this proposed approach, the amount of new homes delivered through neighbourhood plans is an unknown and therefore it is important to ensure the delivery of the minimum number of homes planned for in the Local Plan is in excess of the required 25,500 to allow for this.
Taylor Wimpey therefore consider that 28,050 homes (25,500 +10%) should be planned for rather than the 25,500 currently considered in each of the options that have been identified. This approach would also help to ensure that the requirements of paragraph 68 of the NPPF, which stipulates that council’s should plan for a deliverable supply of land for years 1-5 of the plan plus an appropriate buffer to be identified, will be met.

Housing Requirement
Additional land should be identified to provide a buffer beyond the base number identified in the standard methodology in order to create flexibility and contingency in the supply.

Where Neighborhood Plans have not come forward or have failed at examination, and therefore no development sites have been allocated as is required under the adopted Local Plan, the Local plan should allocate sites to meet this need.

Object

Representation ID: 6372

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 3.1 to 3.5 – OBJECT
Calculation of Bedford’s housing requirement

The current Local Plan 2030 requires that the Council arrange for the development of 970 new homes per year over the Plan period. The proposed new Local Plan 2040 will increase this by 32% to 1,275 new homes per year over the 20 year period of the Plan – a total of 25,500 new homes.

The calculated housing requirement of 25,500 dwellings is equivalent to building around 25 new villages the size of Sharnbrook (approx. 1,000 homes) or six new towns the size of Ampthill (approx. 4,000 homes).

Existing commitments
A full breakdown of existing commitments, referred to as representing 13,000 dwellings (including allocations from current local plans and an allowance for windfall) should be provided so that the accuracy and reasonableness of this figure can be examined. In the absence of an analysis of the forward trajectory upon which this figure is based, the gap between the proposed housing requirement figure and existing commitments cannot be verified.

Key Rural Service Centres
In regard to the allocations from current local plans, CPRE Bedfordshire believe that the substantial inflation of the housing requirement in the 2030 plan as well as this draft 2040 plan has resulted in excessive expectations upon the Key Service Centres of Bromham, Clapham, Great Barford and Sharnbrook. The Council should be challenging the current government advice on the standard method so that the Council’s housing requirement can be recalculated based on the most up to date data from the Office for National Statistics (ONS). This would allow for the current expectations for new housing delivery from the Key Service Centres, currently totaling 2,000 homes, to be reduced by at least 50%.

CPRE Bedfordshire fully recognises the need for new homes for the people of Bedford
Borough and in particular, affordable homes and social housing. However, these huge
numbers are based on inaccurate and outdated 2014 housing data from ONS and the much criticised Standard Method algorithm which the government insist that local authorities use to determine housing need. This is despite considerable disquiet among government MPs and demographic experts, including the highly regarded company Opinion Research Services (ORS), which was responsible for preparing the Council’s Local Housing Need Assessment upon which the draft Local Plan 2040 is based.

ORS point out in the “Bedford Borough Housing Needs Assessment” (HNA) page 12, para 28, that the housing needs of all the people of Bedford Borough over the 20 year Plan period, including those people expected to migrate into the area from elsewhere in the UK, can be met by building 15,442 new homes, a very considerable reduction on 25,500 proposed in the Local Plan.

The government then insist however, that a further 8,877 new homes are added to the
15,442 to encourage even more inward migration into the Borough.

As ORS point out in a comment on page 74 of the HNA para, 6.16:
“This level of inward migration is notable ……… The extra 8,877 dwellings for inward
migration implied by the standard method represents an increase of 88% over and above
the inward migration already included in the most up to date household projection” i.e.
15,442 new homes.

This is a staggering increase with no justification from Government.

The ORS data shows that approximately 70% of the total of 25,500 new homes to be built in
the Plan period are to encourage a massive inward migration of people from elsewhere in
the UK to Bedford Borough.

This is a key part of the Government’s development plans for the OxCam Arc which the Mayor and the Council have signed up to without consulting local people.

These plans will not make housing cheaper or any more accessible for local people – driving
a huge inward migration of people into Bedford Borough will simply increase housing
demand and therefore increase the price of new homes and building land. The only people
to benefit from this will be developers and landowners/speculators.

If accurate, up to date ONS data is used from 2018 Housing Formation analysis, then the calculated housing need for the Borough would be similar to the current Local Plan 2030 housing requirement of 970 dwellings per annum.

CPRE Bedfordshire's position is that we are completely unable to accept the figure of 1,275
new homes per year which will destroy the Bedfordshire countryside at a time of:
• Climate Emergency
• Catastrophe of biodiversity loss - bird species in the UK have dropped by between 40% and 70% in the last 40 years and insect populations by similar numbers and the decline is increasing at pace.
• The UK’s ranking amongst the most nature depleted nations on earth.

The cause of much of this has been the "Growth At Any Cost Agenda" that has been
followed for many years. We urge the Council to reject this agenda and the "business as
usual" approach and to look towards different, more modern and more environmentally
sustainable objectives.

This means turning away from the government’s OxCam housing growth ambitions and
focus on building good quality affordable housing for local people (including a reasonable level of inward migration) and the protection and enhancement of the beautiful Bedfordshire countryside, not its destruction.

Bedfordshire is one of the smallest counties in England but the 13th most densely
Populated. Our countryside is therefore precious.

Comparisons with other Local Planning Authority housing targets

CPRE Bedfordshire has compared Bedford Council’s housing target, which has been calculated using the government’s discredited standard method algorithm, to the housing targets of other surrounding local authorities.

In this comparison, Bedford Council’s housing target of 1,275 new homes per year for the next 20-year duration of its draft Local Plan 2040 is shown to be:
• One of the highest of any local authority in the southeast of England outside of the Greater London Metropolitan area.
• Higher than that of the city of Cambridge or any local authority in Cambridgeshire.
• Higher than the housing target of the city of Oxford or any local authority in the county of Oxfordshire – in fact, it is almost double the target of each local authority in Oxfordshire
• Bedford Council’s housing target is over 30% higher than that of Huntingdonshire District Council, part of Cambridgeshire, and 18% higher than that of South Cambridgeshire Council. (Both of these Cambridgeshire authorities have similar
populations to that of Bedford Borough.)

The counties of Oxfordshire and Cambridgeshire are more than twice the size of Bedfordshire, which is one of the smallest counties in England.

Bedford Council’s housing target is 31% higher than that of North Hertfordshire, 180% higher than East Northamptonshire, 142% higher than Kettering and 266% higher than Wellingborough.

Detailed comparisons are shown in the appendix.

Object

Representation ID: 6387

Received: 13/09/2021

Respondent: Mr Nick Dann

3.0 & 4.0
There is not a shortage of high-quality development opportunities to be included in the LP40. The call for sites by BBC returned over 430 responses totaling >70,000 plots against a need of 12,500 plots for completion of the plan. There is no need to consider the large Dennybrook proposal.

Object

Representation ID: 6441

Received: 13/09/2021

Respondent: Ms Donna Thompson

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: 6461

Received: 13/09/2021

Respondent: Mr Steven Kent

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: 6541

Received: 13/09/2021

Respondent: Mrs Susan Trolley

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: 6545

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

1.11 and Paragraphs 3.1 – 3.3 (Local Housing Need and Levels of Growth)– Comment
2.2 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.
2.3 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
2.4 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”
2.5 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.
2.6 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.
2.7 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
2.8 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: 6564

Received: 13/09/2021

Respondent: Challenger Multi Academy Trust

Agent: Fisher German LLP

Housing Requirement
2.1 The Council propose to utilise base Local Housing Need as established through the Standard Methodology as the adopted housing requirement. The Council conclude that this uplift (from the existing housing requirement) will assist in meeting the wider aims of the Oxford-Cambridge Arc, which advocates for significant growth in housing to ensure economic growth in the region, which is described as being of national importance by the Government, is not fettered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, 1,275 dwellings per annum as established through the standard method. The Council consider having regard for existing commitments, derived from planning permissions, current allocations and a windfall allowance which all equate to 13,000 dwellings, meaning the Council need to positively allocate 12,500 dwellings to ensure Local Housing Need can be met.
2.3 The PPG is clear that when establishing a housing requirement “the standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area… Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” [our emphasis] (Paragraph: 010 Reference ID: 2a-010-20201216). Examples of scenarios which may justify an increase of housing requirement include growth strategies, the delivery of strategic infrastructure improvements or the requirement of an authority to take on unmet need from a neighbouring authority.
2.4 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing requirement from local housing need are necessary should be undertaken prior to and independently from any consideration of the ability of an area to meet that need.
2.5 Within the draft Plan document and supporting documents, the Council do not substantively consider any merits for uplifting Local Housing Need, beyond a brief reference to the Oxford Cambridge Arc at 1.5 of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure is a minimum. The Council set out that it is not possible to positively plan for the increased requirements of the Arc due to the Arc Spatial Framework having been delayed 2 years. We do not consider this to be sufficient reason to not positively Plan for this in the short term. There is currently an initial consultation on the Arc Spatial Framework – ‘Creating a Vision for the Oxford-Cambridge Arc’ – until 12th October 2021 with a draft Spatial Framework due to be published for consultation in autumn 2022, followed by the implementation of a final framework.
2.6 Uplifting on the basis of the Oxford Cambridge Arc, something which is entirely sensible and in accordance with the PPG and the Joint Declaration, signed by Bedford Borough Council. As a constituent member of the Arc, Bedford should be involved in active engagement with the emerging Spatial Framework and as such should be in a position to at the very least estimate the likely level of any uplift forthcoming on the basis of ongoing discussions. The consultation document does not yet indicate a specific locations and levels for growth, however great emphasis is placed on the concern about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Place-making will be at the heart of the Arc utilising the opportunity for it to be “a world leader in sustainable place-making and community living”.
2.7 Even if in due course there is some debate as to the level of update required, the Council could choose a conservative uplift in the interim period. For example, if the level of uplift in the draft document is proposed to be 30%, the Council could seek to positively apply an uplift of 20% as part of this Plan. This is positive, in keeping with the Framework and entirely sensible. A more positive approach at this stage will enable the Council to better Plan strategically for future uplifts, through for example through the delivery of strategic sites.
2.8 It will be an unacceptable position for this Plan to again by caveated by an early review clause, as was the Case in the current Local Plan. This will merely serve to frustrate and slow much needed development.
2.9 It is evident running base Local Housing Need of all Arc Authorities would result in a significant shortfall against the agreed housing target of a million dwellings up to 2050 which are needed to support the economic goals of the Arc. In total, the result of the Standard Method for all authorities is just over 20,000 dwellings per annum. This means it will take around 47 years to reach the housing target, if all authorities simply make provision for base Local Housing Need, 18 years beyond the 2050 target. Using base Local Housing Need, the area will deliver only circa 63,500 dwellings up to 2050, only around 65% of the housing required. It is therefore demonstrable at this stage that base Local Housing Need is inappropriate, and an uplift is required likely in excess of 20%. The later Authorities begin to uplift their housing requirement, the harder it will be to satisfy, as fewer years will remain. We therefore consider that the Council should seek to uplift the housing requirement now in accordance with the emerging Spatial Framework, as is being proposed by other authorities.

Object

Representation ID: 6569

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Housing Requirement
2.1 The Council propose to utilise base Local Housing Need as established through the Standard
Methodology as the adopted housing requirement. The Council conclude that this uplift (from the
existing housing requirement) will assist in meeting the wider aims of the Oxford-Cambridge Arc, which
advocates for significant growth in housing to ensure economic growth in the region, which is described
as being of national importance by the Government, is not fettered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, 1,275
dwellings per annum as established through the standard method. The Council consider having regard
for existing commitments, derived from planning permissions, current allocations and a windfall
allowance which all equate to 13,000 dwellings, meaning the Council need to positively allocate 12,500
dwellings to ensure Local Housing Need can be met.
2.3 The PPG the standard method for assessing local
housing need provides a minimum starting point in determining the number of homes needed in an area
Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher
than the standard method indicates. (Paragraph: 010 Reference ID: 2a-010-20201216).
Examples of scenarios which may justify an increase of housing requirement include growth strategies,
the delivery of strategic infrastructure improvements or the requirement of an authority to take on unmet
need from a neighbouring authority.
2.4 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing
requirement from local housing need are necessary should be undertaken prior to and independently
from any consideration of the ability of an area to meet that need.
2.5 Within the draft Plan document and supporting documents, the Council do not substantively consider
any merits for uplifting Local Housing Need, beyond a brief reference to the Oxford Cambridge Arc at 1.5
of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure is a minimum.
The Council set out that it is not possible to positively plan for the increased requirements of the Arc due
to the Arc Spatial Framework having been delayed 2 years. We do not consider this to be sufficient reason to not positively Plan for this in the short term. There is currently an initial consultation on the Arc
Spatial Framework - until 12th October 2021 with a
draft Spatial Framework due to be published for consultation in autumn 2022, followed by the
implementation of a final framework.
2.6 Uplifting on the basis of the Oxford Cambridge Arc, something which is entirely sensible and in
accordance with the PPG and the Joint Declaration, signed by Bedford Borough Council. As a constituent
member of the Arc, Bedford should be involved in active engagement with the emerging Spatial
Framework and as such should be in a position to at the very least estimate the likely level of any uplift
forthcoming on the basis of ongoing discussions. The consultation document does not yet indicate a
specific locations and levels for growth, however great emphasis is placed on the concern about the
economy and environment. Place-making will be at the heart of the Arc utilising the opportunity for it to
a world leader in sustainable place-making and community living
2.7 Even if in due course there is some debate as to the level of update required, the Council could choose a
conservative uplift in the interim period. For example, if the level of uplift in the draft document is
proposed to be 30%, the Council could seek to positively apply an uplift of 20% as part of this Plan. This
is positive, in keeping with the Framework and entirely sensible. A more positive approach at this stage
will enable the Council to better Plan strategically for future uplifts, through for example through the
delivery of strategic sites.
2.8 It will be an unacceptable position for this Plan to again by caveated by an early review clause, as was
the Case in the current Local Plan. This will merely serve to frustrate and slow much needed
development.
2.9 It is evident running base Local Housing Need of all Arc Authorities would result in a significant shortfall
against the agreed housing target of a million dwellings up to 2050 which are needed to support the
economic goals of the Arc. In total, the result of the Standard Method for all authorities is just over 20,000
dwellings per annum. This means it will take around 47 years to reach the housing target, if all authorities
simply make provision for base Local Housing Need, 18 years beyond the 2050 target. Using base Local
Housing Need, the area will deliver only circa 63,500 dwellings up to 2050, only around 65% of the
housing required. It is therefore demonstrable at this stage that base Local Housing Need is
inappropriate, and an uplift is required likely in excess of 20%. The later Authorities begin to uplift their
housing requirement, the harder it will be to satisfy, as fewer years will remain. We therefore consider that the Council should seek to uplift the housing requirement now in accordance with the emerging
Spatial Framework, as is being proposed by other authorities.

Object

Representation ID: 6600

Received: 14/09/2021

Respondent: Mr Aiden 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: 6623

Received: 14/09/2021

Respondent: Mr Nicholas Flynn

I wish to respond to the Consultation on the Local Plan 2040 principally by expressing concern that the whole emphasis to the Plan seems to be founded on the premise that as many areas as possible should be earmarked for Housing and Employment rather than trying to limit the extent to which the countryside should be increasingly and irrevocably consumed by seemingly endless developments.
I understand that the Council needs to achieve, at least in principle, certain targets in order to fulfil Government requirements but it would appear that Bedford has been overenthusiastic and is setting targets considerably higher that all contiguous Councils in the same East Midlands area. This creates the impression that Bedford Borough actually has a policy, or at least an aim, to create as many development opportunities as possible rather than trying to keep countryside destruction to a minimum.
I appreciate that allocation of areas for some form of development does not automatically mean that all of those areas will see development come to fruition and there needs to be some form of “reserve”. However, over a period of some 18 years to the end of this Plan period there will undoubtably be some Blue Sky opportunities which would, at least in part, make up some shortfall.
It is pleasing, although only correct, that the first priority for any new housing should be existing brownfield sites, of which there are several in Bedford and surrounding areas. However, developers are very wary of such sites and shy away from them if at all possible. There should be some mechanism for making these brownfield areas a first priority although clearly the Council is unable to force the current landowners to accept sale considerations well below their aspirations even if the result is that these sites remain undeveloped for tears to come. Perhaps the Council should consider some forms of inducement in an effort to see such sites come to fruition.

Object

Representation ID: 6626

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

The Strategy Options consultation document sets out that the standard method figure for Bedford Borough is 1,275 dwellings per year or 25,500 dwellings in total. It goes on to state that after existing commitments are taken into account, the Local Plan 2040 needs to allocate land to provide an additional 12,500 new dwellings over the plan period. There are a number of considerations which suggest this figure should be higher.
Firstly, it needs to be recognised that the 25,500-home requirement is the minimum number of homes that need to be delivered over the plan period. To ensure this figure is delivered, there Local Plan will need to build in suitable flexibility and contingency in the land supply by way of over allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays.
An additional allowance of around 10%, which would equate to a further 2,550 homes, would be the minimum contingency that should be built into the land supply – the figure should be higher if there is a greater risk of slippage in the delivery of sites.
There is reference to choice and flexibility in paragraph 1.50 of the consultation document. However this simply relates to potential neighbourhood plans which should not be relied upon to deliver the Council’s housing requirements. Such neighbourhood plans are an unknown and it is essential that the Local Plan plans for in excess of the required 25,500 to ensure the minimum number of homes are delivered.
Secondly, it is unclear whether the allocations in emerging Neighbourhood Plans are included as commitments. There are a number of Neighbourhood Plans at examination with allocations to satisfy the requirements of the adopted Local Plan 2030. There is a chance that some of these Neighbourhood Plans will not be made which could add to the need for the Local Plan to plan for further additional growth – if two to be made are not, this would add 1,000 homes to the requirement, which may have implications for the proposed strategy.
Finally, the Local Plan should give greater consideration to the emerging aspirations for the Oxford to Cambridge Arc, where Bedford Borough sits in a key central area. To realise the economic benefits of the Arc it is likely that additional housing will be required above the Local Housing Need figure to support a growing working age population. Given Bedford’s central position with good access to both Milton Keynes and Cambridge, it is likely to be a key area of demand for housing. Therefore, it is suggested that the implications of this demand are explored further which may lead to the need for additional housing to be planned to avoid negative impacts on existing communities, including worsening affordability.
As set out in the accompanying Vision Document, Denybrook has the opportunity to deliver up to 4,000 new homes to 2040 and approximately 7,000 new homes and the associated infrastructure such and schools, health care and local centres in both cases.

Object

Representation ID: 6644

Received: 14/09/2021

Respondent: Bedford Borough Councillor

GROWTH AND SPATIAL STRATEGY OPTIONS
3.1- 3.7 :
We recognise that the Council has no choice but to follow the revised national standard method of assessment which requires 12,500 new dwellings in the plan period over and above the existing provisions of the 2030 plan which are for 13,000 dwellings. However, we are aware that the standard method is challenged and under scrutiny. Furthermore, as pointed out in the Housing Needs Assessment, the increase is largely due to the anticipated inward migration arising from the Oxford-Cambridge project. This is further evidence of the need to defer the preparation of the plan as the determinants of where that inward migration might go are not within the control of the Council.
We are a densely populated county and the fact that our imposed target for future housing growth greatly exceeds that of neighbouring authorities emphasises the need for this issue to be publicly aired.

Object

Representation ID: 6662

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 3: Growth and spatial strategy option Subsections 3.1 to 3.10
Level of housing growth required: The borough council have proposed a housing requirement of 1275 /yr. Oakley parish have determined that this figure is higher than it should be. According to estimates prepared by Lichfield Planning Consultancy (see Oakley parish submission), the borough council’s figures are higher than those for surrounding Local Authorities and one of the highest outside the London Metropolitan Area. The borough council should produce a further calculation based on up-to-date ONS data to create realistic figures.
SPC are surprised that given the significant disparity between Bedford Borough’s housing ‘target’, when compared to other local or near neighbour authorities, or any authority outside of London for that matter, that the Borough has not already challenged the use of the government methodology by proposing the use of a more accurate estimation model utilising the latest ONS data.
The current housing ‘target’ also seems to include a very significant increase in net migration to the Borough, SPC would question the sustainability of this approach given the very likely negative impact this new demand would have on housing availability and affordability for existing residents. Our expectation would be that a Local Plan should first and foremost be a tool for ensuring future development meets the needs of the local communities within the plan area, and that desirability of migration to the Borough is a reflection on meeting that objective rather than, as it seems right now, inward migration being one of the primary drivers of the local plan.
Growth and strategy Options: SPC has concerns with the significant uplift in the housing target that is being proposed with the Local Plan 2040. Although cognizant that the government standard method of assessment is being proposed, this method has been widely criticised as being potentially flawed given its reliance on stale and out of date data.
It is also not clear how an uplift of 32% from the current LP housing target can be considered environmentally sustainable when the majority of the land to be allocated in the Local Plan is not brownfield but greenfield, with much of it Grade 2 arable land. Given the growing awareness and importance of producing food locally, this approach would appear to be taking Bedford Borough backwards not forwards in terms of Environmental Net Gain.
If BBC is unable or unwilling to challenge the housing targets identified in the proposed local plan then SPC would be generally supportive of the approach detailed under point 3.5, Growth and spatial strategy options.
Stevington Parish Council have reviewed the four options presented in the Development Strategy Topic Paper and the draft Local Plan 2040. SPC welcome the approach of focusing growth of housing in the Southern parishes of the county. However, councilors have concerns over the proposed level of housing developments generally and feel that the number of dwellings should be minimised as far as possible. Of the four options proposed, although there is little difference between them in terms of their direct impact on Stevington Parish, option 2c is marginally preferred as this appears to have the least overall number of planned dwellings. Whichever option is finally chosen, we ask the Borough Council to ensure that the selected minimises carbon emissions and biodiversity loss.
Although the plan indicates there is to be very little additional housing in Stevington parish, SPC are concerned about the increase in traffic flow through the village that will occur from planned growth of 500 homes in each of Bromham, Clapham, Great Barford and Sharnbrook. This needs to be significantly reduced (halved) in each village as the road network will not be able to cope There are particularly concerns regarding levels of pollution from petrol cars, vans and lorries and also increased safety hazards that this growth will bring.
As there is significant uncertainty on how future work and travel patterns are likely to evolve, post COVID-19, as well as the likely impact of the Oxford to Cambridge Arc Spatial Framework to the plan then it would make sense to take a more prudent approach to year on year development delivery targets in the first half of the plan period. This would allow for future validation of the accuracy of the current net migration and housing demand forecasts and allow the remainder of the plan target to be based, in part, on actual real world rather than forecast data.
Given the significant potential impact of EWR on the LP and the future development of Bedford Borough, SPC would question why the Council opted not to include a section for feedback on the route selection as part of the overall LP consultation phase. Most of the new development options have a reliance, at least in part, on the delivery of EWR to provide the supporting infrastructure for connectivity, so would play a major part in the feasibility and delivery of the Local Plan, but opinion on what is a major decision for the Borough community is not being sought? We find this lack of consultation concerning and view this as a missed opportunity by the Borough.

Object

Representation ID: 6677

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

para 3. Growth and spatial strategy options. 3.1 Level of housing growth required.
Cardington Parish Council fully supports the comments of the Campaign to Protect Rural England; Bedfordshire Branch and looks forward to the Borough’s response, either accepting that the Draft Plan’s housing growth level should be substantially reduced or providing a detailed and quantitative case countering the CPRE’s proposals.

Object

Representation ID: 6682

Received: 14/09/2021

Respondent: Willington Parish Council

7. We also note the briefing document prepared by CPRE, the countryside charity which is critical of the use of the Governments discredited Standard Method algorithm. It is astounding that the results of this have resulted in housing targets that are
a. One of the highest of any local authority in the South East of England outside the Greater London Metropolitan area
b. Higher than the City of Cambridge or any local authority in Cambridgeshire (Cambridgeshire is more than twice the size of Bedfordshire)
c. Higher than the City of Oxford or any local authority in Oxfordshire (Oxfordshire is more than twice the size of Bedfordshire)
d. A target 30% higher than Huntingdonshire District Council and 18% higher than South Cambridgeshire (both of which having similar populations to Bedford Borough)
e. 31% higher than North Hertfordshire, 180% higher than East Northamptonshire, 142% higher than Kettering and 266% higher than Wellingborough

Object

Representation ID: 6722

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

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: 6760

Received: 14/09/2021

Respondent: Ms S Kelly

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: 6812

Received: 15/09/2021

Respondent: Mr Damian Smith

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: 6860

Received: 13/09/2021

Respondent: Mrs Joanna Ibbett

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: 6899

Received: 15/09/2021

Respondent: Master Corey T 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: 6924

Received: 15/09/2021

Respondent: Bromham Parish Council

Level of Growth
Other studies have revealed that the growth figures calculated for the Bedford Borough area
are much higher than those for surrounding Local Authorities and one of the highest outside
the London Metropolitan Area. Bedford Borough Council should, therefore, produce a further
calculation based upon the latest ONS data which it is claimed would result in c. 900 homes
per annum. In addition, Bedford Borough Council has exceeded the previous Local Plan
target of 970 homes per annum and the Inspector has confirmed that the overbuild can be
taken forward into the next Plan.

Object

Representation ID: 6991

Received: 16/09/2021

Respondent: Mr Robert 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: 7004

Received: 17/09/2021

Respondent: Biddenham Society

Thank you for your invitation to comment on the draft Bedford Borough Local Plan 2040. Throughout its 50 year tenure, the Biddenham Society has reserved its comment to local development matters rather than those more widely across the Borough or further. On the basis of this and in response to the consultation, I would suggest that, because of the substantial number of new houses built or planned in the Biddenham area over the last 30 years, further construction on any remaining green spaces, paddocks or gardens within the village should not normally be permitted. The emphasis that the plan makes for retaining green spaces should very much remain prominent and of priority in development around the village to retain as much of the remaining openings between buildings as possible. With the extensive plans for building in other areas including the proposed new conurbations, it makes sense not to simply crowd what remaining spaces we have in villages like Biddenham.

Object

Representation ID: 7031

Received: 17/09/2021

Respondent: Mr Robert Tusting

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: 7080

Received: 09/09/2021

Respondent: June 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: 7127

Received: 09/09/2021

Respondent: Stephen 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: 7207

Received: 17/09/2021

Respondent: Mr Peter Knight

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: 7241

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

The Local Housing Need (“LHN”) figure calculated determines the minimum number of homes needed. However that is just the starting point. The PPG is clear that the Standard Method provides the minimum starting point and 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 a higher need than the Standard Method indicates1.
2.3 Such circumstances include where an authority is agreeing to take unmet need from neighbouring authorities or where there are growth strategies in place or where the need for affordable housing is particularly acute.
In this case Bedford Borough Council is part of the Cambridge to Oxford Arc, which is set to see significant economic and infrastructural growth and in turn inward population migration and higher housing need. Whilst the standard method may be a starting point for a housing figure, it need not be the end particularly where there are highly constrained authorities in the arc and as such housing will be required elsewhere.
There is no clear evidence of a Duty to Cooperate and that unmet need within the arc is being handled appropriately by authorities ahead of the Oxford to Cambridge Arc Spatial Framework due for consultation in Summer 2021 (2 years later than expected). Bedford Borough Council should be pro-active in undertaking DtC meetings on publication of the draft Spatial Framework and adjust the draft Plan, including housing requirement, accordingly. These findings should also be reflected and tested in the Sustainability Appraisal.
In this respect the figure of 1,275 dpa as a minimum starting point is considered to be the right approach at the present time, however, through Duty to Cooperate discussions with neighbouring authorities in the arc this minimum starting point is likely to need to increase.