3.1

Object

Representation ID: 8402

Received: 27/09/2021

Respondent: WSP

Agent: WSP

HOUSING NEED
The draft Local Plan asks the question:
“How many homes will be needed to be provided across the plan period?”
As outlined in Paragraph 61 of the NPPF, the standard method should be used to calculate future
housing requirement and Councils must follow this. Bedford Borough Council (BBC) state a result
of the government’s recent revisions to the standard method, the housing requirement for BBC is
1,275 dwellings per year, resulting in a total of 25,500 dwellings for the 20-year period from 2020 to 2040. The Draft Plan indicates that is the current starting point for the Local Plan housing requirement.

When considering existing commitments (planning permissions, allocations from current local plans and an allowance for windfall, which together total 13,000 dwellings), based on the standard method requirement figure of 1,275 dpa, the Draft Plan will need to allocate land to provide a minimum of 12,500 new dwellings.
Further detail is set out in the evidence base document Local Housing Needs Assessment (LHNA), this provides evidence the standard method number for the borough has been altered by recent affordability figures and the LHNA was produced in relation to the previous requirement of 1,305 dpa (a total 26,100 dwellings between 2020 and 2040) and this should therefore be considered as the figure for BBC’s housing requirement per the stand method as defined in the NPPF.
The annual requirement in the adopted Local Plan 2030 is 970 dwellings per year. The 1,305 required dwellings for this new plan represent a substantial increase to the adopted plan and will therefore result in the requirement to allocate additional sites (such as the land off Great Barford High Street) for housing development.

Object

Representation ID: 8408

Received: 03/09/2021

Respondent: Fisher German LLP

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.

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.

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.

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.

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.

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”.

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.

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.

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.

In respect of the draft Plan’s proposal to potentially utilise a stepped trajectory, referenced at 3.5 of the draft Plan, this is something which is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is partially due to the Council’s approach with regard to the previous Plan and adopting a Local Plan with a functional period up to 2030 only, despite the concerns of a number of development stakeholders. It is to us entirely inappropriate that this can be used to fetter current housing needs to later in the Plan period. This approach is particularly considered problematic in that it is anticipated that housing needs will increase through the Spatial Hierarchy, thus further compounding delivery requirements later in the Plan period. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised and in reality, it would likely damage the authority in later years by resulting in an unacceptable annual requirement.

Object

Representation ID: 8449

Received: 03/09/2021

Respondent: Mr Theodore Cassell

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: 8477

Received: 02/09/2021

Respondent: Wates Developments

Agent: JLL

In relation to residential delivery targets, the draft plan identifies that 1,275 dwelling
completions a year are required (a 33% increase on the current adopted plan), for the life of
the plan, up to 2040 (para 3.1).
This figure will need to be kept under review and it is likely the specific strategic
development context of the Borough within the Oxford -Cambridge Arc, this figure will need
to be significantly exceeded.
As noted in the consultation draft Local Plan, the first public consultation by the Government
on the Arc Spatial Framework was planned for summer 2021 which is two years later than
initially anticipated. The Government has now begun this consultation on the Oxford
Cambridge Arc vision, which commenced in July 2021 and which runs until mid-October
2021. The consultation document sets out that that the Spatial Framework Issues and
Bedford Borough Council
Planning Policy Team
Borough Hall,
Cauldwell Street,
Bedford,
MK42 9AP
Our ref Wates/Wixams
Direct line 07922582704
Email tom.lambshead@eu.jll.com
2
Options report will not be published until Spring 2022 with a likely completion at the end of
2022 or in 2023.
It is recognised that this is challenging for the Council as the growth requirements and other
impacts associated with the Arc are currently unknown. Nevertheless, there will no doubt be
a requirement for significant additional growth in the borough and the housing and
employment land requirements are likely to increase significantly. The Local Plan should
plan for a significantly higher housing number as a result (paragraph 3.1 -3.17 inclusive).

Support

Representation ID: 8492

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

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 the increase (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, described as being of national importance by the Government, is delivered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, equating to 1,275 dwellings per annum, as established through the standard method. The Council consider that 13,000 dwellings will be delivered through existing commitments, derived from planning permissions, current allocations and a windfall allowance. As such 12,500 dwellings need to be planned for in the emerging Plan to ensure Local Housing Need can be met.
2.3 The Planning Practice Guidance (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 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. It is also important to note that Local Housing Need is, outside of the 20 largest towns and cities, a policy-off figure, as such delivering base Local Housing Need cannot be said to be delivering policy-on objectives relating to economic growth for example.
2.5 Within the emerging draft Plan 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 paragraph 1.5 of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure
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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, is entirely sensible and is 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. Even if 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 emerging 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.
2.7 It will be an unacceptable position for this emerging Plan to be subject to an early review clause, as is the case in the current Local Plan. Such an approach would merely serve to frustrate and slow much needed development.
2.8 Planning only for the baseline requirement of Local Housing Need for all Arc Authorities would result in a significant shortfall against the agreed housing target of one million dwellings up to 2050 which are needed to support the economic goals of the Arc. The Standard Method, for all authorities, totals just over 20,000 dwellings per annum. To meet the one million dwelling target across the Arc, would take around 47 years if only 20,000 homes per annum are delivered; 18 years beyond the 2050 target. Using base Local Housing Need, the Arch Authorities will deliver only 63,500 dwellings up to 2050; 65% of the housing required. It is clear therefore that planning to meet the base Local Housing Need is inappropriate and an uplift is required likely in excess of 20%. The later Authorities start to uplift their housing requirement, the harder it will be to satisfy, as fewer years will remain to deliver the need. It is therefore considered that the housing requirement should be uplifted now in accordance with the emerging Spatial Framework, as is being explored by other authorities, including West Northamptonshire which has set out that a 40% increase in housing requirement may be necessary to fulfil its housing obligations as an

Arc authority.
2.9 The proposal to utilise a stepped trajectory, referenced at paragraph 3.5 of the draft Plan, is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is primarily due to the approach to reduce the adopted Plan period, to a functional period up to 2030, despite the concerns of the development industry at the time. It is to us entirely inappropriate that these reported difficulties can be used as justification to delay current housing needs to later in the Plan period. This approach is particularly considered problematic in that, as detailed previously, housing needs will increase further; this, combined with stepping the trajectory to deliver increased numbers later in the Plan period will only further compound delivery. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites, including land east of Newton Lane, Turvey, which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised.

Object

Representation ID: 8505

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

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

Support

Representation ID: 8512

Received: 02/09/2021

Respondent: Bedfordshire Police

It is stated that 25,500 dwellings will be required for the period 2020 to 2040, of which 12,500 will need
to be provided by the new Local Plan.
Much of the development will be on open fields, which by definition place little demand on the police
and other emergency services. By contrast, once the population is living at these sites, there will be
significant and on-going demands upon the emergency services permanently.
When looked at from purely a policing perspective, there will be a very big increase (relative to current
rates) in crime and demand (comparable with existing rates in the Borough) from new residents for
policing services across a wide spectrum of support and intervention as they go about their daily lives
at the various sites and across the Borough. This applies whether they are victims of crime or witnesses
to it, involved in car accidents for example, or require the police for some other reason.
These additional crimes, anti-social and public safety/welfare incidents will translate into the following
day-to-day impacts upon BP:
 Additional calls and responses per year via the police control centre.
 Attendance to additional emergency events within the developments and Borough each year.
 Additional non-emergency events to follow-up with public contact each year.
 Additional recorded crimes in the developments and Borough
 Additional anti-social behavior incidents each year within the new developments and Borough.
 Demand for increased patrol cover.
 Additional vehicle use.
 Additional calls on police Airwaves system.
 Additional use of the Police National Database (PND) systems to process and store crime records
and intelligence.
 Additional demands for deployment of mobile CCTV technologies.
Additional demand for use of ANPR technologies.
 Additional demand for local access to beat staff from local neighbourhood teams.
 Additional policing cover and interventions in all the areas described when considering staffing
functions above and for additional accommodation from which to deliver these.
The above explains why it has been necessary to prepare the enclosed BPIP, which should be read in
conjunction with these representations. This is because it identifies and evidences the infrastructure
that will be required by BP to deliver effective policing services to the four potential growth options.
Hitherto BP has absorbed the impacts arising from development and population growth in the Borough
without seeking mitigation from the planning system. As explained and evidenced in detail in the BPIP,
this situation cannot continue as BP does not have the resources or capacity to do so. Further
development growth without any form of mitigation being provided will simply lead to a steady
degradation of BP’s ability to deliver policing services. This is a situation true of the education and health
authorities for example and applies to the emergency services as well.
The methodology used in the BPIP to calculate the police infrastructure impacts arising from the
development growth options has been endorsed by the National Police Chiefs’ Council. It has been
found to be sound by the Secretary of State 12 times and the Planning Inspectorate 31 times following
planning appeals. The most recent decision is dated 12 August 2021. This confirms that the
infrastructure requirements specified by BP are directly related in scale and kind to the development
growth options.
It is noted that the public consultation draft is concerned with seeking responses as to which of the four
options the Council should progress. Whilst BP are a neutral party when it comes to this decision, we
strongly recommend that when detailed planning policies are eventually prepared in relation to the
chosen option, they should set-out the infrastructure required to support it. This should include police
infrastructure in accordance with the detailed evidence and findings presented in the enclosed BPIP.

Object

Representation ID: 8546

Received: 03/09/2021

Respondent: Mrs Claire francis

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: 8618

Received: 13/09/2021

Respondent: Mr Henry 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.

Support

Representation ID: 8654

Received: 28/09/2021

Respondent: Mr Chris Bearman

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 ensuring the wider aims of the Oxford-Cambridge Arc (which advocates significant growth in housing to ensure economic growth in the region, described as being of national importance by the Government) is delivered.
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 that 13,000 dwellings will be delivered through existing commitments, derived from planning permissions, current allocations and a windfall allowance. As such 12,500 dwellings need to be planned for in the emerging Plan 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 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 advises that the consideration of whether uplifts to the housing requirement, beyond 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. It is also important to note that Local Housing Need is, outside of the 20 largest towns and cities, a policy-off figure, as such delivering base Local Housing Need cannot be said to be delivering policy-on objectives relating to economic growth for example.
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.
5
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 Planning only for the baseline requirement of Local Housing Need for all Arc Authorities would result in a significant shortfall against the agreed housing target of one million dwellings up to 2050 which are needed to support the economic goals of the Arc. The Standard Method, for all authorities, totals just over 21,000 dwellings per annum. To meet the one million dwelling target across the Arc, would take around 47 years if only circa 21,000 homes per annum are delivered; 18 years beyond the 2050 target. Using base Local Housing Need, the Arc Authorities will deliver only circa 634,000 dwellings up to 2050; 65% of the housing required. It is clear therefore that planning to meet the base Local Housing Need is inappropriate and an uplift is required likely in excess of 20%. The later Authorities start to uplift their housing requirement, the harder it will be to satisfy, as fewer years will remain to deliver the need. It is therefore considered that the housing requirement should be uplifted now in accordance with the emerging Spatial Framework, as is being explored by other authorities, including West Northamptonshire
6
which has set out that a 40% increase in housing requirement may be necessary to fulfil its housing obligations as an Arc authority.
2.9 The proposal to utilise a stepped trajectory, referenced at 3.5 of the draft Plan, is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is primarily due to the approach to reduce the adopted Plan period, to a functional period up to 2030, despite the concerns of the development industry at the time. It is to us entirely inappropriate that these reported difficulties can be used as justification to delay current housing needs to later in the Plan period. This approach is particularly considered problematic in that, as detailed previously, housing needs will increase further; this, combined with stepping the trajectory to deliver increased numbers later in the Plan period will only further compound delivery. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites, including land north of the A4280 (figure 1), which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised.

Object

Representation ID: 8685

Received: 13/09/2021

Respondent: Mr J Francis

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: 8709

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

3.1 The consultation paper sets out the result of the standard method which is 1,275 new homes per
annum between 2020 and 2040 which means that after taking account of 13,000 dwellings
committed, the new local plan will need to allocate land to provide a minimum of 12,500 new
dwellings.
3.2 Paragraph 7.3 of the Sustainability Appraisal Report states a higher growth figure should be
considered of LHN plus 10%. It states:
“In considering reasonable alternatives for the amount of housing growth to be
provided in the local plan, a lower figure than 12,500 dwellings (or no growth)
is not a realistic option because of the National Planning Policy Framework
requirement for local plans to meet assessed needs in accordance with the
standard method. However this is a minimum number and a higher growth
figure should be considered for the purposes of sustainability appraisal testing.
In the absence of any methodology for calculating a higher alternative figure,
a 10% uplift to the local housing need assessment is proposed. This would give
a requirement for 1,403 dwellings per year and a total of 28,060 dwellings over
the plan period. After commitments are deducted, 15,060 dwellings would
need to be allocated.”
3.3 We endorse this need for a buffer of at least 10%, but it has not been carried forward into the
consultation paper and the options put forward. Whilst we agree that there should be a minimum
10% flexibility, we consider there should be a buffer of 20% which is based on the Local Plans
Expert Group report to the Communities Secretary and to the Minister of Housing and Planning in
March 2016. The report recommends at paragraph 11.4 that the Framework should make clear
that local plans should be required to demonstrate a five year land supply but also focus on
ensuring a more effective supply of developable land for the medium to long term, plus make
provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing
requirement, as far as is consistent with the policies set out in the Framework.
Bedford Local Plan 2040 – Draft Plan Strategy Options and Draft Policies Consultation
Representations for Hollins Strategic Land LLP
September 2021
3
3.4 As the plan moves forward a buffer of 20% is essential given that some of the growth is reliant on
made neighbourhood plans and from experience across the county issues arise on the timing of
delivery on allocated sites. As we set out below it would also assist with the economic aims of the
Arc and deliver much needed affordable homes in Bedford to meet a significant need.
Stepped Requirements
3.5 The Plan suggests that a stepped requirement is being considered. It states:
“Whilst more detailed work will be needed to determine this, we will consider
whether, given the significant investment in infrastructure which would be
necessary to deliver development in the borough at scale, a stepped trajectory
approach may be appropriate for this plan. This could mean, for example, that
the delivery target could be kept at 970 per year until 2030 and then increased
to 1,580 dwellings per year to make up the rest of the plan requirement over
the remaining 10 years. By 2030 the Black Cat Junction improvements will be
complete, the East West Rail section through Bedford Borough will be complete
(including new and re-modelled stations) and sufficient lead-in time will have
been available for strategic projects to be planned in detail, enabling these
higher numbers to be achieved. The forward planning will include
arrangements for new sustainable travel links, with the intention that these are
available from day one in order to embed and promote sustainable travel
choices.”
3.6 We are not against a stepped requirement given the scale of development and the timing of
infrastructure being delivered. However, we consider that the Council must consider the potential
for small and medium sized sites which are not reliant on strategic infrastructure that can deliver
early in the plan period as sustainable extensions to towns and villages rather than pursuing the
stepped requirement at this stage. If a stepped requirement is required, then it should be based
on a trajectory that factors in early delivery on small and medium sized sites and larger allocations
which so not require that new infrastructure. The imperative should be to meet the housing needs
sooner and any stepped requirement should be for new settlements only if they form part of the
strategy going forward. At this stage the presumption should be to plan for 1,275 dwellings per
annum on adoption with monitoring provisions to allow for sites to be brought forward earlier if
delivery does not keep pace with requirement. Housing completions in the recent past suggest
that delivery of 1,275 is achievable in the market with 1,350 dwellings and 1,359 dwellings being
completed in 2017-18 and 2018-19 respectively.
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Should there be an uplift of Housing Requirement?
3.7 Paragraph 61 of the Framework states:
“To determine the minimum number of homes needed, strategic policies should
be informed by a local housing need assessment, conducted using the
standard method in national planning guidance – unless exceptional
circumstances justify an alternative approach which also reflects current and
future demographic trends and market signals. In addition to the local housing
need figure, any needs that cannot be met within neighbouring areas should
also be taken into account in establishing the amount of housing to be planned
for.”
3.8 Paragraph 2a-010 of the National Planning Practice Guidance (NPPG) states:
“When might it be appropriate to plan for a higher housing need figure than the
standard method indicates?
The government is committed to ensuring that more homes are built and
supports ambitious authorities who want to plan for growth. The standard
method for assessing local housing need provides a minimum starting point in
determining the number of homes needed in an area. It does not attempt to
predict the impact that future government policies, changing economic
circumstances or other factors might have on demographic behaviour.
Therefore, there will be circumstances where it is appropriate to consider
whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much
of the overall need can be accommodated (and then translated into a
housing requirement figure for the strategic policies in the plan). Circumstances
where this may be appropriate include, but are not limited to situations where
increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities are encouraged to make
as much use as possible of previously-developed or brownfield land, and
therefore cities and urban centres, not only those subject to the cities and
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urban centres uplift may strive to plan for more home. Authorities will need to
take this into account when considering whether it is appropriate to plan for a
higher level of need than the standard model suggests.”
3.9 As set out above, the minimum local housing need figure under the standard methodology is
1,275 new homes a year for the period 2020-2040. This is a total of 25,500 homes. After taking
account of the existing commitments, the Plan seeks to make provision for 12,500 homes over the
plan period to 2040. However, there should be a critical assessment of the supply undertaken to
ensure that the Submission Plan allocates sufficient land to meet the housing requirement and
that over-estimation of existing commitment delivery does not result in under-estimation of new
allocations. That assessment should be consulted upon prior to the Submission Plan being
prepared and consulted upon.
Arc Spatial Framework
3.10 As noted in paragraph 1.8 of the consultation document, in February 2021 the Government
published a policy paper entitled ‘Planning for sustainable growth in the Oxford-Cambridge Arc:
an introduction to the spatial framework’. They are now consulting on “Creating a vision for the
Oxford-Cambridge Arc” which ends on 12th October 2021. The consultation states that its
purpose is:
“Creating a Vision for the Oxford-Cambridge Arc’, sets out the government’s
first public consultation on the Oxford-Cambridge Arc Spatial Framework. We
are seeking views to help us create a vision for the Oxford-Cambridge Arc
Spatial Framework, and in doing so guide the future growth of the area to
2050.”
3.11 A number of points arise.
3.12 Paragraph 5.5 of the Arc Spatial Framework states:
5.5 We are concerned about the affordability and availability of housing in the
Arc, and what this will mean for the Arc’s communities, economy and
environment. Development of new homes is already happening in the Arc, but
in the main centres this has not kept up with need. We also know people are
being priced out of the area, increasing the need to make more polluting
journeys for work and leisure, and making home ownership less likely for many.
And we have heard concerns about the quality and sustainability of new
development.
3.13 Paragraph 5,7 states:
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5.7 We will also seek to set policies to enable:
• new development to come forward at the scale and speed needed, in
sustainable locations, with a focus on brownfield redevelopment;
• new development to support the recovery of nature, new green space that can
be accessed by all, resilience to climate change, and protection of highly valued
existing green space; and
• housing needs to be met in full, including much-needed affordable housing.
3.14 Paragraph 5.8 states:
“5.8 In parallel to the development of the Spatial Framework, the government
is also exploring options to speed up new housing and infrastructure
development in the Arc to help meet its ambitions, where evidence supports it.
This includes examining (and where appropriate, developing) the case for new
and/or expanded settlements in the Arc, including options informed by possible
East West Rail stations between Bedford and Cambridge and growth options
at Cambridge itself. The government will undertake additional Arc
consultations on any specific proposals for such options as appropriate. The
Spatial Framework will guide the future growth of the Arc to 2050, including on
the question of new housing and infrastructure and will, as part of its
development, take into consideration any significant new housing and
infrastructure coming forward to meet the Arc‘s ambition.”
3.15 It is clear that the Arc Spatial Framework will impact on Bedford and the scale of housing. It is too
early to give significant weight to the Arc Spatial Framework but as the emerging LP2040 is being
prepared in parallel with it and “shares many of the overarching principles relating to economic
growth and the natural environment”, then planning for an additional 20% of housing not only
provides the necessary flexibility required but will also provide homes to meet the economic
ambitions of the Arc Spatial Framework.
Affordable Homes
3.16 In the case of Bedford, paragraph 5.52 of the Local Housing Needs Assessment (LHNA) states that
the affordable needs is 691 dwellings per annum which “represents a substantial proportion of
the annual growth of 771 households per annum identified by the ONS 2018-based household
projections for the LHN period 2020-2030 (10-year variant, Figure 33)”1. It represents 54% of the
standard method figure.
1 Paragraph 5.53 of the LHNA
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3.17 The Standard Method does not assess the affordable housing needs in each LPA area as the
PPG2 confirms where it states:
“An affordability adjustment is applied as household growth on its own is
insufficient as an indicator of future housing need because:
household formation is constrained to the supply of available properties –
new households cannot form if there is nowhere for them to live; and
people may want to live in an area in which they do not reside currently, for
example to be near to work, but be unable to find appropriate
accommodation that they can afford.
The affordability adjustment is applied in order to ensure that the standard
method for assessing local housing need responds to price signals and is
consistent with the policy objective of significantly boosting the supply of
homes. The specific adjustment in this guidance is set at a level to ensure that
minimum annual housing need starts to address the affordability of homes.” (our
emphasis)
3.18 Paragraph: 010 Reference ID: 2a-010-20190220 states:
“Circumstances where this may be appropriate include, but are not limited to
situations where increases in housing need are likely to exceed past trends
because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities will need to take this into
account when considering whether it is appropriate to plan for a higher level of
need than the standard model suggests.” (our emphasis)
3.19 In the case of Bedford, Step 1 of the Standard Method is 980 dwellings per annum, with Step 2
increasing it to 1,275 dwellings. The affordability uplift is therefore 295 homes, which is significantly
2 Paragraph: 006 Reference ID: 2a-006-20190220
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below the 691 affordable homes in the LHNA. This is because the affordability ratio as a long-term
adjustment to house prices which can only be seen at the end of the plan period and is not
meeting those 691 households in need per annum now and throughout the plan period.
Therefore, we consider the Council should apply an uplift to meet affordable housing needs.
3.20 To conclude, our position is that the requirement should be treated as a minimum and a flexibility
percentage should be considered and in the order of 20%. This would give a reasonable degree
of security that should sites not deliver at the rates anticipated it will:
• Help ensure there is a robust five-year housing land supply;
• deliver a greater level of affordable housing in line with the LHNA;
• deliver homes to meet the economic ambition of the Arch Spatial Framework.

Object

Representation ID: 8713

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

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

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

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

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

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


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

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

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


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

Object

Representation ID: 8777

Received: 29/09/2021

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: 8812

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

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: 8849

Received: 29/09/2021

Respondent: Mr Alex Simpson

Agent: Bidwells

Chapter 3 of the consultation document sets out that the standard method figure for Bedford Borough is 1,275 dwellings per year (25,500 dwellings in total) and that after commitments are taken into account, the plan needs to allocate land to provide a minimum on 12,500 new dwellings.
2.2 It is unclear whether the existing commitments that have been identified include the emerging Neighbourhood Plan allocations which will 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.
2.3 It is important to note that the 25,500-dwelling 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. To ensure this figure is delivered, 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.
2.4 It is normal 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 the under-delivery of dwellings. Whilst reference is made to ‘choice and flexibility’ in Paragraph 1.50, this is only in response to the potential additional growth that could come forward via Neighbourhood Plans. The amount of new homes delivered through Neighbourhood Plans is unknown and cannot be relied upon 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.
2.5 We, therefore, consider that 28,050 dwellings (25,500 +10%) should be planned for as opposed to the 25,500 currently considered in each of the options identified. Subject to the strategy to be adopted by the Council including a range of site sizes and locations, this approach would also ensure that the requirements of the NPPF (2021) Paragraph 68, which stipulates that the Council 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.
2.6 Bedford Borough sits in a key central area of the Oxford to Cambridge Arc and as such the Council will need to ensure that the level of growth that is planned for is in line with wider aspirations for the Cambridge-Oxford Arc area. For the economic benefits of the Arc area to be achieved, it is likely that additional housing will be required in order to support a growing working-age population. Should the housing not be provided alongside the economic growth that this anticipated, this may have knock-on impacts for the existing residents in terms of increased housing prices and worsening affordability.
2.7 Therefore, we stress the need to plan for flexibility and contingency, with the broader long-term economic aspirations for growth in the wider area taken into consideration when setting the housing requirement for the Borough.
Summary
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 Neighbourhood 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.
● The Local Plan 2040 needs to be set within a longer-term vision to satisfy NPPF (2021) Paragraph 22.
● The Government’s wider economic growth aspirations for the Oxford to Cambridge Arc and the potential uplift in housing need that this will result in should be thoroughly considered, and it is important to note in relation to this that the standard methodology housing requirement is a minimum figure.

Object

Representation ID: 8863

Received: 29/09/2021

Respondent: Mrs Alison Myers

I am a resident of Ravensden and a member of the Parish Council; these comments are my personal submission.

1. Housing Numbers and the Oxford Cambridge Arc para 3.1
I consider the growth target of 25,500 between 2020 and 2040 to be totally unrealistic and although I understand that the Borough is charged with this number by Government, I would strongly support BBC challenging this target. The concept of the Oxford - Cambridge Arc is flawed ( in my view) as it has failed to take key constraints into consideration, particularly the need to protect BMV land and the ability to supply basic requirements such as water without damage to the environment.
Twenty -five thousand dwellings is roughly equivalent to two towns the size of Sandy. Even if one new settlement was planned, such as Dennybrook, with the rest of the dwellings located in a village scale settlement with additional dispersed growth, the impact on the character of North Bedfordshire would be unacceptable. The loss of BMV land at this scale is contrary to NPPF policies

Object

Representation ID: 8893

Received: 30/09/2021

Respondent: Mr Peter Mills

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: 8941

Received: 01/10/2021

Respondent: Mr James Browning

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: 8973

Received: 01/10/2021

Respondent: Dacorum Borough Council

This Council acknowledges the difficulties of trying to comply with the national standard method in full given the substantial scale of unconstrained need arising from it and also the challenges in achieving alignment with the Oxford Cambridge ARC plan. We note that the draft Local Plan explains that Bedford Borough Council has taken a number of steps in order to meet its housing needs as fully as possible and the need to proceed with the 2040 Local Plan to avoid policies becoming outdated and the explanations behind these are welcomed.

Support

Representation ID: 8981

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

Chapter 3 of the consultation document identifies that 171 hectares of new employment land will be required up to 2040. There are 48 hectares of employment supply identified in the District, it is therefore expected that the emerging Local Plan will need to identify 123 hectares of land in order to meet employment needs.

When planning for employment land required, the Local Plan 2040 should include a buffer in order to allow a choice in the market, alongside a range of site typologies in order to meet different requirements in the market. Whilst Chapter 3 acknowledges that there is a shortfall of 123 hectares of land, a further buffer of 10% should be applied to this figure and therefore the plan should be looking to allocate 135 hectares of employment land to allow for this flexibility.

Bedford Borough is located in the central area of the Oxford to Cambridge Arc. The vision for the Arc anticipates a significant level of residential and economic growth in the local authority as part of wider aspirations for the area. Consideration should therefore be given as to whether there is a need to go beyond the 135 hectares to maximise economic benefits for the area and deliver the arc vision. As is discussed further in the next section, given the limited opportunities for growth around the edge of Bedford, a starting point for this should be ensuring opportunities within the urban area, such as at Manton Lane, are taken to avoid the need to make difficult decisions about the release of agricultural land for development.

Support

Representation ID: 8985

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

2.1 Chapter 3 of the consultation document identifies that 171 hectares of new employment land will be required up to 2040. There are 48 hectares of employment supply identified in the District, it is therefore expected that the emerging Local Plan will need to identify 123 hectares of land in order to meet employment needs.
2.2 When planning for employment land required, the Local Plan 2040 should include a buffer in order to allow a choice in the market, alongside a range of site typologies in order to meet different requirements in the market. Whilst Chapter 3 acknowledges that there is a shortfall of 123 hectares of land, a further buffer of 10% should be applied to this figure and therefore the plan should be looking to allocate 135 hectares of employment land to allow for this flexibility.
2.3 Bedford Borough is located in the central area of the Oxford to Cambridge Arc. The vision for the Arc anticipates a significant level of residential and economic growth in the local authority as part of wider aspirations for the area. Consideration should therefore be given as to whether there is a need to go beyond the 135 hectares to maximise economic benefits for the area and deliver the arc vision. As is discussed further in the next section, given the limited opportunities for growth around the edge of Bedford, a starting point for this should be ensuring opportunities within the urban area, such as at Manton Lane, are taken to avoid the need to make difficult decisions about the release of agricultural land for development.

Object

Representation ID: 8990

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

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

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

Reasoning
Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’
refers to the importance of the role of the NPPF to deliver the economic pillar of objectives
for the corridor. In principle this reflects use of the Standard Method as the expected starting
point to identify housing needs within the Arc but further reflects observations in the initial
consultation and the role of the PPG that may necessitate delivery of higher levels of housing,
setting out considerations such as:
“developing an Economic Strategy, supported by strong economic evidence, to
identify the policies, locations and investment needed to deliver the Arc’s potential
for sustainable and green economic growth; and
• setting policies to make sure growth is felt by all communities and the Arc becomes
a better place to live and work for all, such as by providing more housing in the
right places, making sure people can move around by public transport and other
infrastructure, and enhancing the Arc’s natural capital”
The main implication of this component of the Arc Spatial Framework reflects circumstances
where the calculation of local housing need will not result in sufficient workers in the right
locations to achieve the full potential of sustainable patterns of economic development.

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

In-particular, the Council’s Employment Topic Paper:
• Does not use a range of economic forecasts (utilising only the East of England
Forecasting Model (EEFM2019) baseline scenario only)
• Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
• It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment
land scenarios set out no assumptions on economic activity rates or commuting -
the baseline EEFM assumptions are not dissimilar to LHN in terms of additional
dwellings and persons required to meet the jobs forecast).
• It takes no account of engagement with the LEP or forecast Spatial Framework
scenarios (that may result in a higher demand for labour)
Remedy
Failure to take account of these factors means that the Local Plan 2040 is more likely to
result in conflict with the emerging priorities of the Arc Spatial Framework and it is
recommended that a range of jobs-led scenarios are tested prior to determining the housing
requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 9014

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Housing Growth
4.5 Whilst the starting point of the Local Plan in determining the housing requirement for BBC is the Standard Method figure of 1,275 dpa, we can expect that BBC will required to plan for even more growth under the OxCam Arc Spatial Framework.
4.6 The live consultation for the Arc does not set out specific housing targets and therefore the individual housing targets for authorities within the Arc are currently unknown. However, based on the NIC report ‘Partnering for Prosperity’ (2017), it is likely that at least a 45% uplift is needed to help secure economic transformation across the Arc16.
4.7 BBC has acknowledged this change on the horizon (see paragraph 1.5 of the Development Strategy Topic Paper below):
“specific growth requirements and other impacts associated with the Arc are not yet known. In spite of this, councils such as Bedford are being pressed by MHCLG to continue the preparation of their Local Plans in parallel with the Arc work. The consequence of this is that the Arc spatial strategy will not be finalised in time to inform the preparation of this Plan and the Council must focus on meeting its own growth requirements as set out above”
4.8 Recognising the current lack of synchronicity in timings, changes to the NPPF since the 2040 Local Plan consultation launched means that the new visioning work will be forced to grapple with this issue. Whilst it is acknowledged that BBC cannot plan for a specific uplift figure, it is clear from the work conducted by the NIC that there will need to be a significant uplift, (notionally c 45%) that will need to take place across the Arc authorities to facilitate the level of economic growth that can potentially be achieved in the Arc. As such, it is considered that BBC should take a more proactive approach and be more forwards looking with regards to their housing need, and start to consider sites that can deliver an additional quantum of housing later on and in the post plan period which will help the Arc to achieve its sustainable growth aspirations.
4.9 A more recent example of housing requirements being increased above the Standard Method within the Arc is the consultation on the Oxfordshire Plan 2050. The Growth Needs Assessment produced in respect of this Plan (July 2021) confirms that the Standard Method figure for housing across Oxfordshire would only be 3,400 dwellings per annum. However, the GNA recognises that should Oxfordshire continue to grow economically at the levels it has been historically, a housing need of c 4,100 dpa would arise, with this increasing to c 5,100 dpa under the terms of the Growth Deal set out by the Oxfordshire Authorities in 2017.
Constraints in the Arc
4.10 Bedford is located centrally within the Arc and will be heavily influenced by the Government’s preparation of a Spatial Framework for the area. Bedford is relatively unconstrained compared to the other Arc authorities, notably Oxford and Cambridge which have seen significant levels of
housing and employment space growth and are both heavily constrained by Green Belt which might limit further expansion.
4.11 BBC also benefits from the inclusion of stations on the East West Rail line (EWR), the major role of which will facilitate links to high employment areas of Cambridge and Milton Keynes. These relative strategic advantages that Bedford enjoys would suggest that Bedford may well be considered by the Arc as a focus for additional levels of housing growth above those set by the Standard Method and TwinWoods remains a key option to achieve this.