3.3

Object

Representation ID: 3542

Received: 08/08/2021

Respondent: Mr Mark Hilliard

Given the uncertainty around the new retail model post covid (potentially yielding additional brownfield developments if there is no demand for large central retailing outlets) and population growth with Brexit, I believe a sensible plan would initially stick with the plans to support the existing requirement. As society adapts to the changes, the Council should develop a phased approach - initial plans based on the current requirements, with the ability to expand to the new figures in the second half of the planning period if needed.

Object

Representation ID: 3860

Received: 27/08/2021

Respondent: Oakley Neighbourhood Planning Group

500 homes in each of Bromham, Clapham, Great Barford and Sharnbrook in the current Local Plan is too high and should be reduced to 250 in each village as the road network will not be able to cope. In addition, Bedford BC has exceeded the previous Local Plan target of 970 homes p.a. and the Inspector has confirmed that the overbuild can be taken forward into the next Plan.

Support

Representation ID: 3977

Received: 29/08/2021

Respondent: Anne Dorber

Conversion of excess retail space and office space may be helpful here, especially in providing town centre housing, which may reduce travel requirements. However, this needs to be quality conversions, with good space, natural light, ventilation and insulation standards and access to dedicated green space.

Object

Representation ID: 4063

Received: 30/08/2021

Respondent: Ann Mills

The basis for calculating housing need must be a realistic assessment of actual need not needs determined by the artificial manipulation of housing markets to increase demand.

Object

Representation ID: 4592

Received: 01/09/2021

Respondent: Mr Denis Ivins

the figure of 1,275 new homes per year will destroy the Bedfordshire countryside at a time of climate emergency and where the Uk is aseen as the most nature depleted nations in the world.

Object

Representation ID: 5252

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: 5288

Received: 03/09/2021

Respondent: Mr Jetinder Dhaliwal

Does this mean the local housing need may go up as well as down ? Is this considered in the annual figure already quoted?

Object

Representation ID: 5384

Received: 03/09/2021

Respondent: Mrs Clare Buddle

When do the community get consulted? If details are contained in the submission draft, this will be too late for a reasonable , democratic discussion.

Support

Representation ID: 5931

Received: 08/09/2021

Respondent: Mr Tom Tagg

I support the continued review of the 1,275 figure.
As my responses to 3.1 and 3.2 above, I ask that BBC do all they can to challenge the standard method and to use contingency wherever possible to reduce this number.
I would hope that with agreement of the Ox-Cam Arc Spatial Strategy, housing requirements will be spread evenly and fairly across the Arc, to avoid further overheating of hotspots such as Bedford, that has already contributed 3x the national average growth. In addition integrated planning with Central Beds and Hunts DC, may reduce this excessive figure.

Object

Representation ID: 6159

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Paragraph 3.3 states that the Council will keep the Local Housing Need figure under review and will change
the figure as necessary at the time that the plan for submission is prepared. There has to be a cut-off point
for this process and for this to be explained by the Council.

Object

Representation ID: 6184

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 1.11 and Paragraphs 3.1 – 3.3 (Local Housing Need and Levels of Growth)– Comment
2.13 Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the Government’s Standard Method provides the starting point for assessment of the number of homes to be provided through Plan-making. Positive Plan-making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the Standard Method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.
2.14 It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.
Reasoning
2.15 Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the Standard Method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:
• “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
• setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”
2.16 The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.
2.17 In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.
2.18 In-particular, the Council’s Employment Topic Paper:
• Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
• Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
• It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting - the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
• It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)
Remedy
2.19 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: 7441

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

Section 3 of the document is of considerable interest to our client. For those reasons
set out above it is our position that the overall housing target should be increased to
account for several external factors. These factors have been discussed at length in
the comments provided on the content of the DS and the LNA. However, our client
does take comfort from Para 3.3 of the LP which acknowledges that the local housing
need figure will change as necessary at the point of the plan’s submission.