Issues and Options

No

We write to you on behalf of our client, Manor Oak Homes, and further to our response to the Council’s Call for Sites exercise in respect of their land between Hookhams Lane and Ravensden Road, Salph End. Specifically, we are pleased to provide a further response in respect of the Issues and Options (I&O) consultation document which represents the first step of the review of the Local Plan 2030. Accordingly, the comments provided by this letter should be read in the context of our client’s ongoing promotion of our client’s land at Salph End. It is being promoted for a development of approximately 400 dwellings and a site for a new two forms-of-entry primary school, land that the Call for Sites submission confirms is available, deliverable and eminently achievable with delivery able to commence in the earliest years of the new plan period. This promotion follows on from a rigorous level of engagement with the Council during the preparation of the Local Plan 2030 and draws support from a recent planning application at the site which is now subject of an ongoing appeal. In light of our comprehensive submission to the Call for Sites it is not intended to review the merits of our client’s site again as part of this submission. Our response to the general questions set out in the I&O document, however, will be predicated on the availability of our client’s site for development and the clear opportunity it presents to secure a substantial and entirely sustainable new residential community on the northern edge of the Bedford urban area. Background to the Local Plan Review Prior to setting out our response to the general questions posed by the I&O document it is worth confirming the context of this review of a local plan only adopted 7 months ago, in January 2020. A brief overview of the need for the review is set out at pages 3 and 4 of the I&O document. However, to allow us to establish the proper context of the review it is useful to highlight the precise quotes of the Local Plan 2030 Inspectors. The pertinent passage of their report explaining the need for Policy 1 of the Local Plan 2030 securing its immediate review is as follows: “16. However, notwithstanding these cited reasons, in the medium – long term, and in particular after 2030, the proposed ‘Cambridge – Milton Keynes – Oxford Arc’ is likely to have significant implications for Bedford, particularly in terms of the need for housing, employment land and infrastructure. Nonetheless, there is currently insufficient clarity about these implications to include in the plan effective, detailed policies and proposals on development and infrastructure needs reflecting the Arc. Therefore, whilst the NPPF 2012 indicates that plans should take account of longer-term requirements, given the current uncertainty about development and infrastructure needs in Bedford post 2030, it would not be effective to, at the present time, extend the plan period beyond 2030. On this basis the plan is, therefore, also consistent with the NPPF 2012 requirement that plans should be drawn up over an appropriate time scale. 17. Nevertheless, there is a need for the plan to respond appropriately to longer term requirements, and in particular the Arc, as soon as possible. Consequently, notwithstanding the statutory requirement for the plan to be reviewed, and then updated if necessary, within five years of its adoption, it is necessary for a review and update to be completed more quickly. On this basis (and for other reasons detailed elsewhere in this report), MM1 is necessary for the plan to be justified and effective. This requires a review of the plan and any update of it/new plan to be submitted for examination within three years of adoption of the current plan. Based on the discussion at the hearings the three year deadline appropriately balances the need for the plan to be reviewed and updated as quickly as possible with the realities of the time likely to be necessary for the Council to effectively undertake this work.” These comments essentially recognise that the Local Plan 2030 represents a strategy that is fit for purpose for a short moment in time only. It is sufficient to provide an up-to-date policy framework capable of meeting an immediate need for a set of policies more in line with the requirements of the NPPF in light of it replacing a 12 year old development plan framework. In short, the plan is a stopgap. In respect of even the basic growth requirements for the Borough moving forward, before any uplift relating to the Arc is factored in, the Inspectors’ report went on to observe: “As set out in the Introduction of this report, the plan is being examined under transitional arrangements detailed in NPPF 2019. These mean it is not being tested for its compliance with this document’s statement that, other than in exceptional circumstances, the minimum number of homes within a plan area should be determined using the standard method detailed in national planning guidance (i.e. the updated PPG). The standard method identifies an annual minimum housing need figure for Bedford of around 1,280 dpa, more than 30% higher than the plan’s objectively-assessed need of 970 dpa. The two housing need figures are formulated using different approaches and, thus, at the present time and given the transitional arrangements for the examination of local plans, the 1,280 dpa figure does not undermine the robustness of the 970 dpa objectively-assessed need figure for new housing in Bedford.” Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 3 The Local Plan 2030 was adopted under a set of transitional arrangements designed to ensure that emerging plans could successfully negotiate their examinations without the need for a wholesale review in respect of either the baseline objectively assessed housing need or the approach taken by the Council in the production of the plan. What this has resulted in, however, is a strategy which now proposes a supply of new homes which falls significantly short of the actual up-to-date requirements of the Borough. As will be demonstrated as part of our client’s ongoing appeal this quirk has resulted in the current Local Plan 2030 only being able to facilitate the delivery at best 80-85% of the Borough’s housing needs, based on the lower 970 dwelling per annum figure of the adopted plan, over the current 5-year period. On this basis the central objective of the new Local Plan subject of this I&O consultation is clear – to significantly boost the supply of new homes across the Borough in a way that the Local Plan 2030 failed to achieve. This will ensure that the replacement strategy accommodates significant and ambitious growth through the identification of a range of deliverable sustainable sites that are currently absent from the adopted development plan. Set on this foundation we now seek to address what we consider to be the most relevant questions posed by the I&O document, Questions 2 and 4 relating to the draft vision for the plan and the appropriate spatial distribution of growth.

The draft vision, as the mission statement for the plan, lacks ambition. It also does little to describe the way in which the new local plan will significantly up a gear in respect of housing and infrastructure delivery. Currently as written it could be mistaken as the vision which underpins the current Local Plan 2030, one which includes an aspirational but likely unachievable focus on housing delivery at the Borough’s town centre sites and which dodges the need to identify a wide range of immediately deliverable development opportunities on the fringes of the Bedford urban area. Also, bearing in mind that one of the key reasons for the immediate review of the Local Plan 2030 is the implications of the Oxford Cambridge Arc the omission of any reference to this growth strategy is questioned. Whilst it is acknowledged that there is still limited confirmation of the true objectives of the strategy for the Arc there is no question that the corridor represents a critical area of growth in the south east with Bedford Borough at its fulcrum. Reference is made in the vision to connectivity to both Oxford and Cambridge but, as worded, the vision does little to describe how critical growth in and around Bedford will be to achieve the objectives set out in the Arc-related Joint Declaration dated March 2019 of which Bedford Borough Council was a signatory.

Brown – Urban based growth , Grey– Dispersed growth

Objectively Assessed Housing Need Firstly, prior to commenting on the various growth options presented in support of this question it is important to clarify the appropriate range in respect of dwelling numbers that the plan should be based on. Currently, the I&O document states the following as an approximation of the growth target for the Borough: Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 4 “Bedford’s annual housing requirement calculated in accordance with the standard method is currently 1,305 dwellings per annum. If the end date of the plan is 2040, using this figure there would be a need to plan for 26,100 dwellings over a 20 year plan period. It is important to note, however, that during the course of the plan preparation period this figure may change. There are two reasons for this. Firstly, the Government figures for affordability are published annually (and may therefore change when new data is published in March 2021); and secondly, the Government has announced that it intends to review the standard methodology in its entirety in the course of this year. Taking account of these uncertainties this consultation seeks views on a housing figure in the range of 800 –1,305 dwellings per annum. It should be borne in mind that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum. The 800 figure represents an estimate of the possible figure were the standard methodology to be reviewed and based on the 2018-based population projections rather than the 2014-based figures.” Since the publication of the I&O document the situation in respect of the Government’s Local Housing Need calculations has in fact moved on. There is now a current consultation into a revised methodology set out within the Government’s ‘Changes to the Current System’ paper, comments on which are invited until 1st October 2020. Central to the revised methodology is the way in which the Government can continue to ensure that the national annual target of 300,000 homes continues to be achieved. The revised methodology focuses on three issues: the physical capacity of a local area to assume additional homes (i.e. is it an urban or rural area); the current affordability of new homes locally; and the change in affordability over the preceding 10-year period. This ensure that areas capable of accommodating growth do and areas that have seen an escalation of the affordability ratio, indicative of increasing demand, do more to accommodate these trends. Currently, and based on the consultation draft of the revised methodology, Bedford’s projected annual housing figure is 1,153 dwellings1. This factors in a significant uplift that recognises both the current issues in respect of affordability and the fact that this situation has in fact worsened over the last decade. Accordingly, then, the indicative range upon which the Borough’s emerging housing requirement should be based is 1,153 to 1,305 dwellings per annum. Based on a 20-year plan period until 2040 and taking into account existing commitments of approximately 11,000 dwellings this results in a revised residual requirement for the plan period of between 12,000 and 15,000 dwellings by way of new allocations. This is before any additional uplift relating to strategies such as Arc-related growth are factored in on top. It is clear that a significant task lies ahead for the Council in respect of accommodating what will be a significant amount of growth over the plan period. The Appropriate Spatial Strategy Based on the huge scale of required growth it is imperative that the spatial strategy of the plan is driven by the identification of demonstrably deliverable sites rather than the type of complex and often aspirational development opportunities that were considered during the course of the preparation of the Local Plan 2030. The Council encountered repeated difficulties throughout the production of the current plan due to an over-reliance on the proposed new settlement at Sharnbrook. Even once the plan received an endorsement from the presiding 1 The starting point prior to adjustment is the higher of either Bedford’s annual household growth based on the 2018 projections (623.1 dwellings) or 0.5 of the 2019 estimate of housing stock (378.3 dwellings). So 623.1 x [(AR (9.2) – 4 / 4) x 0.25) + (2019 AR (9.2) – 2009 AR (7.1) x 0.25) + 1] = 1,153 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907215/200805_Changes_to_the_current_planning_system_FINAL_version.pdf Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 5 Inspectors their report cast clear aspersions over the deliverability of elements of the current framework of sites with a particular level of doubt applied to the prospects of both the land at Ford End Road and South of the River. It of course did not escape our attention that the Council had earlier deleted eminently deliverable and entirely sustainable development options from the plan such as our client’s land at Salph End principally on the basis of both the new settlement and the urban sites delivering quickly. The evidence now before us suggests that these decisions were miscalculated – indeed, the inadequacy of the adopted spatial strategy and series of allocations is one of the main reasons for such an early review of the plan. Decisions on the eventual spatial strategy of the plan must, then, be substantially informed by the availability of sites and the evidence put forward at Call for Sites stage that provides the Council with certainty that they are available and deliverable. The Strategic Housing Land Availability Assessment (SHLAA) comprising part of the evidence base of the plan must represent the starting point in considering whether each of the spatial options presented in support of Question 4 are viable. From our client’s perspective they are pleased to once again present their own site, land between Hookhams Lane and Ravensden Road, Salph End, as a spade-ready opportunity to deliver a substantial sustainable extension, comprising up to 400 dwellings and a site for a new primary school to the north of the Bedford urban area. The credentials of this site were recognised by the Council prior to its identification as a draft allocation in the 2017 Consultation Document published as part of the Local Plan 2030 process. The graphic supporting the urban option includes hatching identifying a combination of sites around the periphery of Bedford and at the centre of the town it is inevitable that any additional allocations required to support this strategy would be urban edge. Few options of scale beyond the stalled allocations included in the Local Plan 2030 existing within the urban area. Table 1 which accompanies the list of options recognises this, that the brown option would largely entail urban edge development. Curiously, however, it identifies this as a factor that would count against this strategy. We disagree – the identification of suitable and sustainable urban edge greenfield sites would ensure both deliverability and swift access to the strategic highway network. The principal objective of the new local plan is to ensure the 13,000 to 15,000 additional homes required across the Borough can be delivered from the earliest years of the plan period.

Conclusions As set out above we acknowledge that the Council has a significant task ahead to deliver a plan which can facilitate the delivery of a significant escalation of housing growth. To an extent this problem is partially a result of what we consider to be the Council’s unwillingness to prepare a more ambitious growth strategy as part of the adopted Local Plan 2030. By way of an example, in the event that our client’s land had been retained as one of the large urban extensions at the town it is likely that its delivery would have now progressed to the point that first completions on site could Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 6 be expected within the next year. We urge the Council to take a more positive stance when identifying the spatial strategy of the next plan with a clear focus on delivery. On this basis, and recognising the availability of a site capable of accommodating an immediately deliverable residential-led scheme comprising 400 dwellings and land for a new primary school under the control of our client, we commend the Council to pursue a strategy which allows for growth on the urban edge of Bedford. Specifically, we recommend either the urban focused or dispersal options as a priority. An additional point that is covered by the I&O document but is not subject of a specific question is the housing target for the plan. Following the publication of the Government’s draft replacement standard methodology there is now greater clarity in respect of the level of growth that the Borough will be required to accommodate – between 13,000 and 15,000 additional homes. Once the final version of the formula is published, we urge the Council to run a further consultation seeking views on the housing target for the plan area specifically and how provision should be made for additional growth relating to the Oxford Cambridge Arc. As is made clear by the Inspectors overseeing the Local Plan 2030 the ability of the replacement plan to accommodate growth resultant of this strategy will be critical, particularly as the revised plan period is to run until 2040. We trust that the enclosed information is helpful and of a sufficient level to allow our client’s views to be taken on board at this stage. However, should you have any queries or require any further information to assist this process, do not hesitate to contact me. Otherwise, we look forward to continuing to engage with the emerging Local Plan Review process as it unfolds. Yours faithfully