Issues and Options

Yes

We broadly support the scope of the Local Plan review. It is of vital importance that this review utilises updated guidance relating to establishing a robust housing requirement based on Local Housing Need derived from the Standard Methodology. In August 2020, the Government published its proposed updated methodology for undertaking the standard methodology for consultation. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. It should however be recognised that Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement and should therefore be treated as a minimum figure the Borough needs to plan for. Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council advises that the Government have not specifically set out that Bedford needs to increase its housing requirement (as is the case for all authorities), the publication of the proposed revised Standard Methodology illustrates that without upward adjustment, the joint ambition to deliver a million new dwellings to 2050 within the Arc, will not be met. If all of the Arc authorities use the base Local Housing Need, as established from the Standard Methodology, the 2050 target will not be met, with a shortfall of over 156,000 dwellings. This can be easily remedied by increasing the level of growth above the Local Housing Need in each Authority to meet the shortfall, through negotiation, or by simply increasing the housing requirement proportionately. For example, Bedford’s Local Housing Need is 4% of the entire Arc, so 4% of 156,000 dwellings would lead to an upward adjustment of 6,240 dwellings; a further 208 dwellings per annum to 2050. This would align with the Governments ambition to significantly boost the supply of housing.

I agree with this plan period

We would generally agree that for a strategic plan of this nature a Plan period of 20 years (2010-2040) would be appropriate. However, Bedford’s location within the Oxford-Cambridge Arc is in our opinion, sufficient justification to take a differing approach. The NPPF at paragraph 22 outlines that “Strategic Policies should look ahead over a minimum of 15-year period, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure”. There is however no upper limit applied and as such it is up to the discretion of the LPA to plan for an appropriate timeframe having regard for its localised circumstances. All constitute Council’s within the Arc have agreed to the Joint Declaration of Ambition between Government and the Arc and as such should act in a way which aligns with this declaration. The seventh paragraph of the declaration states “We recognise that meeting all these ambitions for the Arc requires us to take a long-term view, at least to 2050…”. Given the significant housing, employment and infrastructure requirements required to deliver the aims of the Arc, we consider taking a more strategic, long-term view to not only be pragmatic, but paramount to ensuring the Arc’s aims are realised. Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, it is clear that there will need to be a substantial increase in housing delivery across the Arc to ensure this target can be delivered. This increase will need to commence early within the Plan period and continue throughout. To deliver this uplift late within the -Plan period through increases in housing requirements or stepped trajectories, simply pushes back delivery. Therefore, to achieve the objective of a swift step change in delivery it is important that a mix of sites is allowed within the Plan to cater for locations where demand is high to allow swift delivery within the Plan period. Looking beyond 2040 enables the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term.

Nothing chosen

The Consultation Document sets out six potential options for the spatial distribution of growth through the Local Plan review, these include urban based growth, A421 based growth, rail growth, east-west rail growth, dispersed growth and new settlement-based growth. The consultation document also sets out that any eventual strategy could be a combination of the above options. It is considered that there should not be any significant reliance on strategic sites, particularly in the form of new villages/settlements. Strategic sites, including new villages, could be included as a facet of the supply, but any Plan which relies on the timely delivery of a number of strategic sites forming the largest component of supply is unlikely to deliver. New settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. Richborough Estates have previously made reference to the NLP ‘Start to Finish’ report which confirms the above and advises that the determination period of a planning application over 500 dwellings is in the order of 5.3. to 6.9 years. The report advises that “Planned housing trajectories should be realistic, accounting and responding to lapse rates, lead-in times and sensible build rates. This is likely to mean allocating more sites rather than less, with a good mix of types and sizes, and then being realistic about how fast they will deliver so that supply is maintained throughout the plan period. Because no one site is the same – and with significant variations from the average in terms of lead-in time and build rates – a sensible approach to evidence and justification is required.” If a new settlement is allocated within the Plan, then caution must be applied when calculating proposed build-out rates and this must be supported with sufficient other methods of delivery to insure the Plan against non-delivery, for example smaller sites which can deliver quickly. It is noted that the Council previously promoted a strategy of delivering new settlements as part of the preparation of the adopted Local Plan, but this ultimately failed and the site deleted from the Plan late in the day, as the viability and deliverability had not been fully considered. As a consequence the Plan period was reduced to address the shortfall created. With regards to placing greater focus on delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building concurrently in one area. Given the number of allocations and permissions already in place, the Council must have evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure capacity. Whilst increased densities around public transport nodes or in urban areas is a way of increasing housing numbers and can be appropriate in certain circumstances, regard must be had for issues relating to design, the need to deliver family homes and housing quality. This a point made in the final report of the Building Better, Building Beautiful Commission which states a need to promote a ‘gentle density’ in the urban area. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. Whilst there is no particular objection to basing growth around planned transport infrastructure, clearly such infrastructure is likely to have capacity limitations and over reliance on such may cause significant issues relating to capacity and congestion. Notwithstanding this, it limits the geographical spread of development, which can place undue impacts on infrastructure and capacity of services and facilities. We consider that the eventual strategy could be a combination of the listed options but consider it must include an element of dispersed growth. Dispersed growth has a number of advantages and cannot be fully excluded in any adopted strategy. The Council’s adopted strategy promotes a level of dispersed growth. Moreover, in the development of the adopted Local Plan, the Council did consider, and at one stage prefer, a strategy of greater dispersed growth, including higher levels of growth directed to Rural Service Centres. We consider the Council should revisit such proposals, particularly in light of the increased housing requirement and the need to have regard to its position within the Oxford-Cambridge Arc, which is likely to see the housing requirement further increase by at least 200 dwellings per annum (thereby an overall requirement of circa 1,360 dwellings per annum). Smaller sites in sustainable locations, such as Turvey, will deliver quickly, which will enable the Borough to respond quickly to the increase in housing requirement. As a number of large sites are already allocated in the adopted Local Plan, this should be balanced with additional sites being allocated for less than 100 units in the emerging Plan which can come forward quickly and assist the Borough in housing delivery, affordable housing delivery and maintaining their housing land supply. By allocating sites in the Rural Service Centres the Borough would secure a mixture of sizes to ensure development can be brought forward to meet local and Borough wide needs. In addition, delivery of housing in the Rural Centres will seek to ensure the vitality and viability of existing services and facilities in the villages. In settlements such as Turvey which currently has a falling school role, due to an aging population, this is particularly important. As set out previously the Council has previously recognised the benefits that development in these settlements can deliver to existing services and facilities.

I disagree

Whilst we support the Council’s aim in reducing climate change, we would not wish to see significant requirements and complication added to the development process. It is clear from the Planning for the Future White Paper that it is the Governments ambition to reduce and simplify the documentation produced by the local government, and not reproduce guidance and policies provided at a national level. Any further guidance must be justified and have regard for the viability of new development.

We are unaware of evidence to support the need to go beyond building such national standards. If the Council is to attempt to introduce such standards, compelling justification would be required as to why standards should be higher than that set at a national level.

Introduction These representations are prepared on behalf of Richborough Estates in respect of their land interests at Newton Lane, Turvey as illustrated on Figure 1 below. The site has been previously promoted through the various stages of the development of the adopted Local Plan and is being promoted through the ongoing preparation of the Turvey Neighbourhood Plan (recently the subject of Regulation 16 Consultation). Figure 1 – Site Location Plan The adopted Bedford Local Plan was adopted under the transitional arrangements of the updated National Planning Policy Framework (NPPF) (2018 and 2019) and as such the housing requirement was based on the objectively assessed need (OAN) delivered through the 2016 Strategic Housing Market Assessment (SHMA). The provisions of the Framework now require as part of this review, that the Council utilise the Standard Methodology for assessing local housing need as the starting point for establishing a new housing requirement. This results in a Local Housing Need of 1,305 dwellings per annum. The government has however published for consultation proposed amendments to the Standard Methodology, which would reduce the Local Housing Need to 1,153 dwellings per annum. Irrespective of whether this approach is adopted, or what the transitional arrangements are, the figure remains the starting point and can and should be increased to account for other factors, such as the Authorities location in the Oxford-Cambridge Arc. This means as a minimum the annual increase in housing requirement is circa 180 dwellings per annum above the current requirement of 970 dwellings; a step change in delivery.