Issues and Options

Yes

It is noted that this consultation includes a revised housing figure provided as a range between 800-1,305 dwellings per annum. However, there is no consideration within this Local Plan consultation in regards to the suitability of these figures. It is centrally important to consider the Local Housing Need requirement in order for an appropriate and sustainable level of growth to be identified and provided for across the Borough, delivering a sufficient amount of housing within the plan period. The requirement for an early review of the Bedford Borough Local Plan 2030 was recognised through the main modifications with the inclusion of Policy 1S. The policy requires the Local Plan 2030 to be reviewed much sooner than usual: a review is required within a year, and a new plan to be submitted for examination within three years of the Local Plan 2030 being adopted. Within the Inspector’s final report, it was recognised that the Standard Method figure was circa 30% higher than current housing figure in the Local Plan 2030. The expectation was that the housing need figure would increase in order to accommodate the anticipated growth from the Oxford to Cambridge Arc. Rather than providing a housing figure of 1,305, based on the current Standard Methodology, (which is some 35% above the currently adopted Local Plan 2030 figure of 970 dwellings per annum) the range of 800 -1,305 has been considered for a number of reasons. These include the Governments figures for affordability, published on an annual basis, are subject to change when new data is published, as well as the Government has announced its intentions to review the Standard Method in its entirety, which is currently out for consultation. Whilst it is accepted that these are uncertainties, the Local Plan should be based on a figure which is in accordance with the agreed method of the time, which in this case, is the current Standard Method approach based on the 2014-based population projections. Furthermore, the Governments figures for affordability are likely to fluctuate in any given year. The Local Housing Need figure when calculated using the Standard Method can fluctuate year to year based upon the housing projections and the SM doesn’t take account of economic growth. Furthermore, if using a range is the preferred approach to the Local Housing Need, it may be more appropriate to use the current standard method figure as a base for the range, with the higher end to be set using an economically led figure which could include the additional dwellings for the Oxford to Cambridge Arc and an appropriate buffer. The Local Housing Need figure as calculated utilising the proposed new Standard Method approach has predicted c.1,153 dwellings per annum may be required across the Borough, some 300 dwellings more than the suggested 800 figure. It is not appropriate to use a figure (800) based on a calculation which has not, as yet, been confirmed. This figure would also provide some 170 dwellings less than the current Local Plan 2030, which was only adopted in January 2020. This will set an unrealistically low target and is unlikely to provide a sustainable amount of housing over the plan period, leading to further housing shortages and affordability problems. Therefore, it is unlikely the plan will be sound if using a figure lower than the current housing need figure in the current local plan. In addition, Paragraph 60 of the NPPF states that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” It is important to note that Paragraph 60 of the NPPF and the associated guidance within the PPG are clear that the standard method represent the “…minimum number of homes needed…” Considering the uncertainty currently surrounding the additional growth due to the Oxford to Cambridge Arc, it is likely that there will be a higher need for housing than that which is currently proposed in the adopted Local Plan and may even be higher than the allowance provided for within the current Standard Method. Furthermore, the plan must respond to the Governments key objective of boosting the supply of housing, which a plan utilising a lower housing figure is unlikely to achieve. It is important that there is flexibility in the number of housing allocations, to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance. In addition, a buffer should also be provided in order to maintain flexibility and to take into account any fluctuations that may occur on a yearly basis. A 5% buffer above the top range is unlikely to be sufficient, just as the Local Housing Need can fluctuate, so can the buffer that is required in regards of the five-year housing land supply. Usually, with a confirmed five-year housing land supply, a 10% buffer would apply, unless the rate of deliverability falls over the plan period, in which case a 20% buffer would apply. To ensure the plan is future proofed and enough flexibility, choice and competition has been provided for in the housing market, in order to reflect government guidance, we consider that a 20% buffer in addition to the top range of housing need, would provide this. Any Local Plan currently under review or in current consultation will also have to consider the effect of the coronavirus pandemic on the housebuilding industry, and subsequently the deliverability of the Council’s current five-year housing land supply. Whilst still relatively unknown, delays in the deliverability of housing are likely and therefore a subsequent undersupply may occur. The Plan must be aspirational but deliverable to be positively prepared (NPPF, paragraph 16) and in order to be found sound, the Local Plan should be targeting higher growth, rather than less than the current target within the Local Plan 2030. Currently, the Local Plan 2030 relies on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, whilst a number are in progress, only two have been ‘made’. Any delays to these emerging neighbourhood plans, could stall the delivery of housing within the Borough. Furthermore, the two which have been ‘made’ are based on the current Local Plan 2030 housing need of 970 dwellings per annum. These ‘made’ neighbourhood plans are likely to require reviewing, to ensure their compliance with any new Local Plan and potentially higher Local Housing Need. It was also highlighted in the Inspector’s final report on the Local Plan 2030, that another reason for the early review of the plan was due to the uncertainty of the preparation and adoption of the Neighbourhood Plans within the timescales envisaged on the housing trajectory. (Para 123) Finally, Neighbourhood Plans are not subject to the same, stringent examination as Local Plans and therefore the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.

Nothing chosen

In order for sustainable growth to be delivered across the Borough at the level that is required, the local plan strategy is likely to need a combination of elements from all the various potential areas of growth identified in Table 1. Whilst a larger proportion of housing and employment growth should be focused on the urban or improved infrastructure areas, growth should also be located within the more rural areas, within smaller scale settlements, such as rural service villages, that have previously been considered as sustainable. Considering the potential uplift required from the Standard Method, it likely that the Neighbourhood Plans which have been ‘made’ will be in need of reviewing, in order to not restrict growth in these locations or for the plans to not be in accordance with the new Local Housing Need. These settlements should contain sufficient services and facilities to meet every day needs of future residents, accepting that in more rural areas future residents may need to travel in the most sustainable way to get to these services and facilities. In addition, sustainable development across the Borough, would help to assist in maintaining the vitality of rural areas including the retention of services and facilities that depend on economic growth. This is especially the case within Bedford Borough, where there is likely to be growth in currently more ‘rural’ areas, in line with the potential Oxford to Cambridge Arc. Often, the sites which would be considered as ‘dispersed growth’ are smaller and can be delivered at a faster rate than the larger, allocated sites. Such sites form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow the Council to continuously maintain a healthy and constant supply of deliverable sites. By combining the options provided in Table 1, this would ensure that there was a level of housing growth across the Borough in areas where those houses are needed. It would promote housing in future economic growth areas and strategic corridors so that economic growth and housing delivery can be developed as a comprehensive strategy rather than a staged process. It would also ensure that rural areas received appropriate growth levels to maintain and enhance economic vitality and the services and facilities required would be maintained.