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New search2.1 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 attained from the Standard Methodology. In August 2020, the Government published its updated methodology for undertaking the standard methodology. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement. 2.2 Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council sets out 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 revised Standard Methodology shows 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, this 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 to the level of housing need. 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, only 208 dwellings per annum up to 2050. This would align with the Government’s ambition to significantly boost the supply of housing.
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 4 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. 2.4 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. 2.5 Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, as set out above, 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 also need to begin early in the Plan period and continue throughout. It is unlikely to be able to deliver this uplift by late-Plan period increases in housing requirements or stepped trajectories, this simply pushes back delivery. 2.6 Looking ahead further allows the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term. Whilst not a statutory development plan document, the Leicester and Leicestershire Strategic Growth Plan offers a good example as to how looking at a longer timeframe can assist in meeting strategic needs. 2.7 To deliver the required levels of housing over the Plan period, the Local Plan review may need to make provision for further strategic urban extensions to existing urban areas, that will inevitably deliver later in the Plan period. This includes sites such as Land West of Box End. However, there should not be an overreliance on such delivery and this should remain a single facet of overall supply. 2.8 Across the Arc itself, there is again likely to be some reliance on significant allocations to assist in increasing delivery rates. If they are to be delivering at pace before 2050, having regard for research on lead in times for strategic development and recent experience within other Arc authorities, plans 5 will need to look for suitable sites at a priority. As such, it is an entirely pragmatic approach to take to plan ahead to 2050, to ensure any necessary strategic sites have sufficient lead in time set out before being expected to deliver. Not having sufficient strategic sites allocated in a timely manner will almost certainly frustrate development in the longer term, particularly 2041-50.
2.9 The Consultation Document sets out 6 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. 2.10 We do not agree there should be any significant form of reliance on strategic sites, particularly in the form of new villages. 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 considered to be problematic. Such a strategy lacks flexibility and the failure of even a small number of sites could have significant impacts on housing delivery. In particular, new free-standing settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. 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. 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 ultimately concluded such an approach was not appropriate. Land at Box End is considered to comprise of urban based growth; such allocations should also be supported by dispersed growth. 2.11 With regards to placing greater impetus on further delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building concurrently in one urban area. The Council must demonstrate evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure 6 capacity. 2.12 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 and housing quality. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. 2.13 Whilst we do not have any 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. 2.14 We concur that the eventual strategy could be a combination of the listed options.
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 Government’s 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.
2.1 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 attained from the Standard Methodology. In August 2020, the Government published its updated methodology for undertaking the standard methodology. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement. 2.2 Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council sets out 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 revised Standard Methodology shows 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, this 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 to the level of housing need. 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, only 208 dwellings per annum up to 2050. This would align with the Government’s ambition to significantly boost the supply of housing.
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 4 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. 2.4 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. 2.5 Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, as set out above, 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 also need to begin early in the Plan period and continue throughout. It is unlikely to be able to deliver this uplift by late-Plan period increases in housing requirements or stepped trajectories, this simply pushes back delivery. 2.6 Looking ahead further allows the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term. Whilst not a statutory development plan document, the Leicester and Leicestershire Strategic Growth Plan offers a good example as to how looking at a longer timeframe can assist in meeting strategic needs. The site is in a sustainable area within Kempston and would constitute a brownfield site, therefore there is sufficient infrastructure and facilities / amenities existing already to support the development of the site. 2.7 To deliver the required levels of housing over the Plan period, the Local Plan review may need to make provision for further strategic urban extensions to existing urban areas, that will inevitably deliver later in the Plan period. However, there should not be an overreliance on such delivery and this should remain a single facet of overall supply. Allocating sites within the Bedford Urban Area is another facet of overall supply that should be considered. 5 2.8 Across the Arc itself, there is again likely to be some reliance on significant allocations to assist in increasing delivery rates. If they are to be delivering at pace before 2050, having regard for research on lead in times for strategic development and recent experience within other Arc authorities, plans will need to look for suitable sites at a priority. As such, it is an entirely pragmatic approach to take to plan ahead to 2050, to ensure any necessary strategic sites have sufficient lead in time set out before being expected to deliver. Not having sufficient strategic sites allocated in a timely manner will almost certainly frustrate development in the longer term, particularly 2041-50.
2.9 The Consultation Document sets out 6 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. 2.10 We do not agree there should be any significant form of reliance on strategic sites, particularly in the form of new villages. 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 considered to be problematic. Such a strategy lacks flexibility and the failure of even a small number of sites could have significant impacts on housing delivery. In particular, new free-standing settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. 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. 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 ultimately concluded such an approach was not appropriate. The development of Land South West of Williamson Road would comprise of urban based growth,; such allocation should also be supported by dispersed growth. 2.11 With regards to placing greater impetus on further delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building 6 concurrently in one urban area. The Council must demonstrate evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure capacity. 2.12 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 and housing quality. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. It is considered the site would support existing infrastructure and service / amenities and it would not lead to undue pressure or significant adverse impact. 2.13 Whilst we do not have any 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. 2.14 We concur that the eventual strategy could be a combination of the listed options.
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 Government’s 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.
