1.35

Object

Representation ID: 5921

Received: 08/09/2021

Respondent: Mr Tom Tagg

While I fully recognise the need for new homes for the people of Bedford Borough and particularly affordable homes and social housing, these huge numbers are based on completely inaccurate and outdated 2014 housing data from the Office for National Statistics (ONS) and a much criticised “Standard Method” algorithm which HMG insist that that Local Authorities use to determine housing need.
This is despite considerable disquiet among government MPs and demographic experts including the highly regarded company Opinion Research Services (ORS) which has prepared BBC’s Local Housing Need Assessment – part of this Local Plan 2040.
ORS point out in the Bedford Borough Housing Needs Assessment (HNA) page 12, para 28, that the housing needs of all the people of Bedford Borough over the 20 year Plan period, including those people expected to migrate into the area from elsewhere in the UK, can be met by building 15,442 new homes, a very considerable reduction on 25,500 proposed in the Local Plan.
HMG then insist however, that a further 8,877 new homes are added to the 15,442 to encourage even more inward migration into the Borough. As ORS point out in a comment on page 74 of the HNA para, 6.16:“This level of inward migration is notable …… The extra 8,877 dwellings for inward migration implied by the “Standard Method” represents an increase of 88% over and above the inward migration already included in the most up to date household projection” i.e. 15,442 new homes.
This is a staggering increase with no justification from Government.
The ORS data shows that approximately 70% of the total of 25,500 new homes to be built in the Plan period are to encourage a massive inward migration of people from elsewhere in the UK to Bedford Borough - a key part of the Government’s development plans for the Ox-Cam Arc
These plans will not make housing cheaper or any more accessible for local people – driving a huge inward migration of people into Bedford Borough will simply increase housing demand and therefore increase the price of new homes and building land. The only people to benefit from this will be developers and land owners/speculators.
If accurate, up to date ONS data is used from 2018 Housing Formation analysis, then housing need in the Borough would be roughly the same as the current Local Plan 2030 level.
I am completely unable to accept the figure of 1,275 new homes per year which will destroy the Bedfordshire countryside at a time of Climate Emergency and when the UK is now ranking amongst the most nature depleted nations on earth.

Object

Representation ID: 7437

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

It is urged that the LNA is kept under constant review as additional evidence comes
to light. It is further urged that the document be reviewed as further detail becomes
clear regarding the Government’s agenda for planning reform and information relating
to the Oxford to Cambridge Arc is released.
The document undertakes a thorough assessment of those individuals and
households who are considered to be in housing need currently and provides detailed
forecasting in regard to those housing needs which will need to be met up to 2040.
Page 9 of the document makes it clear that over the life of the emerging plan there is
a need for 6170 affordable dwellings, which equates to a delivery rate of 309 affordable dwellings per annum. This is a step change from the 238 affordable
dwellings per annum which were constructed in the Borough between 2014 and 2019.
It is considered that to increase the delivery of affordable housing a step change in
overall housing delivery is required. Between 2016 and 2019 the MHCG Live Table
1800C shows that the average number of affordable properties as a percentage of
overall housing delivery in the Borough was 20.875%.
The LNA states that 6170 affordable dwellings are required between 2020-2040 this
is representative of 49.36% of the total strategic housing requirement (12,500) up to
2040. Clearly, this is a significant increase which will need to be pragmatically
addressed.
When taking into consideration the requirements of adopted policy 58S Affordable
Housing, which sets the affordable housing requirement of 30% on sites over 10
dwellings, there would need to be 20,566 dwellings constructed (on sites over 10
dwellings) during the period 2020-40 to ensure that these affordable housing needs
are met. Subsequently, it is considered that the emerging LP’s strategic housing target
should be revised in light of this significant need for affordable housing.
In further assessment, the LNS provides an evidenced based calculation which seeks
to establish an overall housing need figure for the Borough up to 2040 and concludes
that the plan should seek to deliver 26,100 dwellings up to 2040. Accounting for the
current commitments (13,000) this leaves a balance of 13,100 dwellings which is 600
dwellings greater than the amount planned for within the emerging LP.
Notwithstanding the comments relating to affordable housing delivery, the evidence
base contains sufficient justification for the adoption of an increased housing target. It
does however suggest that the target within the emerging plan should be more
ambitious to ensure a boost to the housing supply is achieved.

Object

Representation ID: 8068

Received: 03/09/2021

Respondent: Mr and Mrs Davies

Agent: Aragon Land and Planning

It needs also to be recognised the current Health and Adult Social Care provision is underpinned by a principle of sustaining people living and remaining in their own homes for as long as possible. This approach has with the reduced funding has seen smaller care home provision reduce in Bedford Borough.

The BBLHNA acknowledges (para 7.17) people want to remain in their own general needs housing. However, the evidence does then not go on to address the matter and provide an approach as to how housing policy provision could achieve that end. It also makes far more sense if people as they age can remain in their local community and downsize where they have family and support bubbles.


The evidence focuses on older housing with care provision in the form of sheltered and extra care, but not on providing smaller private retirement schemes located in communities. Some of this housing need not be affordable but can provide for decent retirement housing and achieving national planning policy and social care objectives.

Section 7 of the Issues and Options plan needs to take a wider remit and consider older persons housing and smaller style housing so communities can stay together. The Policy SB1 is silent on the retirement housing and a criterion could be added detailing the approach for custom built retirement housing.

Such sites could be allocated in neighbourhood plans in addition to other housing sites, but also it needs to be accepted they could come forward irrespective of neighbourhood plan allocations.