3.2

Object

Representation ID: 3471

Received: 25/07/2021

Respondent: Mr Peter Gell

If you are increasing the density of housing, you need to be mindful that such developments will not be suitable in all locations without substantially changing the look and feel of the locality. Its become clear during Covid that people want more space not less space, so shouldn't the aim to provide affordable housing without compromising on space.

Support

Representation ID: 3859

Received: 27/08/2021

Respondent: Oakley Neighbourhood Planning Group

Council supports housing development on small sites and would want windfall sites and conversion of empty retail/office properties to housing to be included in housing numbers. Brownfield sites should also be specifically prioritised and grades 1, 2 and 3a agricultural land should not be used for development unless no other sites are available.

Object

Representation ID: 4061

Received: 30/08/2021

Respondent: Ann Mills

‘Affordability figures’ do not, in themselves, mean there is an unmet demand for housing. They just mean house prices in some areas are higher than the regional or national averages. But the reasons for this are often various and building more, cheaper housing will not necessarily result in an increase in demand if there are not other reasons, such as employment, educational, social or environmental for attracting new residents to a particular area or community.

Object

Representation ID: 4590

Received: 01/09/2021

Respondent: Mr Denis Ivins

a better breakdown should be provided so that the accuracy and reasonableness of this figure can be examined.

Support

Representation ID: 4860

Received: 02/09/2021

Respondent: Mr Jon Digweed

I would query the method of calculation of housing need based on information produced by CPRE

Object

Representation ID: 4997

Received: 02/09/2021

Respondent: Rainier Developments Limited (Bromham)

Agent: Marrons Planning

The Council will need to demonstrate in its evidence base that existing commitments can be delivered within the plan period, and these will also need to be set out within the proposed trajectory as indicated to be provided at paragraph 3.4. The trajectory will of course need to be realistic as required by national policy (NPPF paragraph 73), and should have regard to the evidence from Start to Finish Two (Lichfields Feb 2020).

Object

Representation ID: 5008

Received: 02/09/2021

Respondent: Rainier Developments Limited (Roxton)

Agent: Marrons Planning

The Council will need to demonstrate in its evidence base that existing commitments can be delivered within the plan period, and these will also need to be set out within the proposed trajectory as indicated to be provided at paragraph 3.4. The trajectory will of course need to be realistic as required by national policy (NPPF paragraph 73), and should have regard to the evidence from Start to Finish Two (Lichfields Feb 2020).

Object

Representation ID: 5020

Received: 02/09/2021

Respondent: Rainier Developments Limited (Wootton)

Agent: Marrons Planning

The Council will need to demonstrate in its evidence base that existing commitments can be delivered within the plan period, and these will also need to be set out within the proposed trajectory as indicated to be provided at paragraph 3.4. The trajectory will of course need to be realistic as required by national policy (NPPF paragraph 73), and should have regard to the evidence from Start to Finish Two (Lichfields Feb 2020).

Object

Representation ID: 5251

Received: 03/09/2021

Respondent: Mr Peter Norris

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

Object

Representation ID: 5930

Received: 08/09/2021

Respondent: Mr Tom Tagg

With the excessive housing requirement set by the standard method, BBC need to mitigate this with the contingencies that they currently hold. Specific examples are:
• Brownfield land at Stewartby – BBC have only allocated a small part of this for development. The remainder that is held as contingency should be allocated to the additional growth needed for Local Plan 2040, thus reducing the 12,500 new dwellings needed.
• Windfall sites; The Small Sites Topic Paper demonstrates that for the last 5 years BBC easily meets it’s 10% housing requirement on small sites by windfall development. Windfall development is held as a contingency outside the current plan allocation. In the face of the excessive standard method demands, BBC should include windfall development of 10% within the additional 12,500 dwellings needed thus reducing this figure by approx. 1,250 houses.
• The Small Sites Topic Paper demonstrates an expected excess of small sites over the 10% requirement to 2040 of 920 houses. This should also be used to reduce the 12,500 figure.
By the above three items the 12,500 figure could be easily reduced to below 10,000 new dwellings for allocation in Local Plan 2040. This would then be a very similar number to the 970 new homes annual requirement in the adopted 2030 plan, thus requiring little, if any, allocation of new development to meet the excessive Local Plan 2040 requirements.

Object

Representation ID: 6158

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Growth and Spatial Strategy
Paragraph 3.1 in the consultation local plan, states:
“Government guidance sets out a standard method for calculating future housing requirements, which the
Council must follow. As a result of the government’s recent revisions to the standard method, the figure for
Bedford borough currently is 1,275 dwellings per year, giving a total of 25,500 dwellings for the 20 year
period from 2020 to 2040. This is the current starting point for the local plan housing requirement.”
Paragraph 3.2 goes on to state that the new local plan will need to allocate land to provide a minimum of
12,500 new dwellings. This follows deductions for existing commitments and a windfall allowance. The
minimum 12,500 dwellings represents just under 10 years of supply under the minimum local housing need.
This is not soundly based because it does not follow publication of a review of existing commitments to know
whether these new homes will be delivered as envisaged. There is no delivery trajectory or forecast included
within the consultation version of the local plan and there should be.
The December 2020 Indicative Housing Need for Bedford Borough published by the Government identified a
figure of 1,305 dwellings per year. As the Planning Practice Guidance states at 2a-010 this is just the starting
point which is often described as the minimum. There needs to be an explanation of what options the
Council has looked at and discounted for whatever reason within the consultation document. The Council will
need to explain whether there is sufficient housing being proposed to support future economic growth,
especially given the location within the Oxford-Cambridge Arc. We acknowledge that the new local plan and
the spatial framework are not entirely aligned in terms of timescales but nonetheless it is important for the
emerging new local plan to acknowledge the commitment of the Government to the Arc and in particular the
status of Bedford as an area where additional growth and investment is anticipated. An example of this is the
East-West Rail line and stations.
We consider that the Council should factor in a buffer in terms of housing supply to ensure that it can meet
minimum needs, and any in addition, taking into account the need to deliver economic growth.

Support

Representation ID: 6475

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

We agree that the Standard Method is the starting point for the Borough’s local plan housing requirement and that the eventual housing need figure will need to be informed by an updated Local Housing Needs Assessment. The allocation of land to provide a minimum of 12,500 new dwellings will also need to include additional land allocations to ensure choice and competition in the market for land and account for any fluctuations in the market. We consider this whole plan buffer should be at least 10% to meet these objectives in accordance with Paragraph 74 of the NPPF 2021. Based on the Standard Method alone, this buffer will require sufficient land allocations for 15,050 new dwellings. The application of this buffer is missing in the draft Local Plan and its absence means that appropriate levels of growth are not being fully tested and planned for in the various development strategy options. In establishing the Borough’s housing requirement, it is also important to recognise that the standard methodology represents the minimum number of homes that must be planned for. In addition, the Council will need to consider whether there are any unmet needs from neighbouring areas or whether there are scenarios that would lead to housing needs being higher than that established using the Standard Method. One such scenario is the high level of employment growth and investment being targeted in the area through the South East Midlands Strategic Economic Plan (SEMSEP) and Oxford-Cambridge Arc Economic Prospectus – both of which aim to double GVA by 2050. The government’s recent ‘Creating a vision for the Oxford-Cambridge Arc’, sets out a clear focus on making the most of the economic potential of the Arc by planning for sustainable growth to 2050 and beyond and creating a Spatial Framework that is ambitious, aspirational and unique to the Arc. To facilitate such growth the government has already invested in the East West Rail Project, connecting Oxford to Cambridge via Milton Keynes and Bedford and making it easier to connect businesses, research institutions and foster sustainable, economic growth. It is clear that housing delivery will need to keep apace with this economic growth. Will this be accounted for in the next iteration of the draft Local Plan (Regulation 19 stage) or will it will be subject to a separate strategic plan? Clarity on this essential in the interests of achieving the timetable set out in the Local Development Scheme.

Object

Representation ID: 6601

Received: 14/09/2021

Respondent: Mr Aiden Farmer

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8017

Received: 24/09/2021

Respondent: Mr Larry Gooch

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8018

Received: 24/09/2021

Respondent: Mr Larry Gooch

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
3.4 100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 8480

Received: 27/09/2021

Respondent: Richborough Estates

Agent: Fisher German LLP

he 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.
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.
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.
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.
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 1.5 of the Development Strategy Topic Paper (June 2021), which acknowledges that the 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, with a publication anticipated in the Summer 2021 and a target to be finalised by 2023. This is not considered to be a sufficient reason to not positively Plan for this in the short term.
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 plan for 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 a 20% uplift as part of this emerging Plan. This is positive, in accordance with the Framework and entirely sensible. Taking a positive and flexible 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 emerging Plan to be subject to an early review clause, as is the case for the current Local Plan. Such an approach would merely serve to frustrate and slow much needed development.
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.