Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 5611

Received: 07/09/2021

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

The current draft Local Plan 2040 out for consultation does not include any housing allocations for the borough, however it is noted that these will come forward in the next draft version, following the Call for Sites exercise which has previously taken place. We consider it essential for the Council to over-allocate housing land to ensure flexibility, choice and competition in the housing market, reflecting the government guidance including the requirement to significantly boost the supply of housing as per the NPPF.
Whilst the spatial strategy is still being formulated and which has been considered above, it is considered that due to the higher housing need figure of the Local Plan 2040, compared to the Local Plan 2030, then we consider it is likely that more rural areas such as Oakley are to be subject to either housing allocations or reviews of neighbourhood plans to reflect the significantly higher housing need figure. Development in these sustainable but more rural areas would help to meet the identified need and help support the rural economy.
Our client’s site at Land West of Pavenham Road, Oakley was submitted as part of the Call for Site’s exercise and is identified as Site 702. There is a willing landowner who has previously submitted an outline planning application under reference 20/00433/MAO and an appeal with an indicative plan showing how the site could accommodate dwellings. Although the previous outline planning application was subsequently refused and also dismissed at appeal, taking the comments of the Inspector into account, the site can still be considered suitable for a small-scale residential development, which could be focused to deliverable housing for a specific group, for example affordable or over 55’s housing, and can also respond to the existing character of the village.
None of the technical reports completed for the outline planning application and appeal indicate that there are on site issues that would prevent the sites allocation for residential development. There are no significant abnormal or major infrastructure requirements. The Full Policy Requirements for Planning Obligations are expected to be made as evidenced by the Outline Planning Application. There is no indication of any viability issues here.
The site forms a natural extension of the settlement being directly adjacent to the existing settlement boundary and there are no major contraints or viability matters to prejudice the development or allocation of the site for housing. There are no legal issues. The landowners are party to a promotion agreement with Land Allocation Ltd. Consequentially, the site is deliverable, available and developable now.
Please refer to the

Object

Representation ID: 5612

Received: 07/09/2021

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

In regards to housing need, currently there is no policy which identifies the housing need for the area. However,
Paragraphs 3.1, 3.2 and 3.3 identifies that based on the standard method for assessing local housing need, this provides an annual housing need figure for Bedford Borough of 1,275 dwellings per annum, giving a total of 25,500 dwellings for the 20 year period from 2020 to 2040, which is the starting point for the local plan housing requirement.
Paragraph 3.2 states that taking into account existing commitments and windfalls, the figure of 1,275 dwellings per annum will see the new local plan needing to allocation land to provide a minimum of 12,500 dwellings. 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 Bedford Borough, delivering a sufficient amount of housing over the plan period. It is noted that this consultation includes a housing figure of 1,275 dwellings per annum, however, there is no real certainty within this Local Plan consultation in regards to the suitability of these figures. A key government objective is to ‘significantly boost’ housing supply, and it is felt a greater emphasis should be placed on the wording of the policy so that it is recognised as the minimum housing requirement. In fact, the figure of 1,275 dwellings per annum is less than the identified need in the Local Housing Needs Assessment, which considered that 1,305 dwellings per annum would be required. It is understood that this change has been adjusted in accordance with the recent affordability figures.
Paragraph 61 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 me 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 61 of the NPPF and the associated guidance with the PPG are clear that the standard method represents the “…minimum number of homes needed…” The plan must respond to the Governments key objective of boosting the supply of housing. It is important that there is flexibility in the number of housing allocations to ensure that a five-year hosing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over-allocation housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance.
Any Local Plan currently being prepared 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 Council have calculated the annual housing need figure, based upon the Standard Methodology resulting in 1,275 dwellings per annum, or 25,500 dwellings for the period up to 2040, which is actually less than what was identified in the Local Housing Needs Assessment with the adjustment deriving from recent affordability figures. However, it is important to recognise that the need figure, when calculated using the Standard Methodology, can fluctuate year to year, based upon housing projections, and the Standard Method does not take into account economic growth. Indeed, the decrease in the housing need figure from the LHNA reflects these fluctuations. Therefore, we recommend a Housing Requirement calculated by the Standard Methodology, and a requirement which takes into account the economic growth that this plan has identified, detailed further below.
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Just as the Local Housing Need can fluctuate, so can the buffer that is required in the context of five-year housing land supply. The Borough Council may decide to confirm their five-year housing land supply, in which case a 10% buffer would apply, and the deliverable rate may also fall over the plan period, in which case a 20% buffer would apply. We consider that a 20% buffer would ensure than the plan is future-proofed and provide flexibility, choice and competition in the housing market, reflecting government guidance. We cannot see that t his draft Local Plan 2040 nor the Local Housing Needs Assessment give any indication of the buffer the Council considers it will apply.
The draft Local Plan 2040 still relies upon Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. Since the last consultation, it is noted that six have now been formally ‘made.’ We maintain that any delays to emerging neighbourhood plans could stall the delivery of housing within the Borough. Furthermore, those which have been ‘made’ are based on the Local Plan 2030 housing need of 970 dwellings per annum. With a proposed housing need figure of 1,275 dwellings per annum in the Local Plan 2040 review, these ‘made’ neighbourhood plans are likely to require reviewing, to ensure their compliance with the new Local Plan or its review and the higher housing need. Furthermore, we maintain that 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.
We consider that the Council should be targeting a higher housing requirement than the Local Housing Need calculated using the Standard Methodology. It is notable that the proposed requirement does not provide an uplift for economic growth. Paragraph 3.8 considers that taking into account planning population growth to 2040, 171 ha of employment land will be needed by 2040. Whilst there is a currently available supply of 48 ha, this leaves a requirement of 123 ha to be allocated in the Local Plan. Paragraph 3.9 continues to state that the Local Plan must also plan for other growth requirements that may arise, for example additional shops and services, schools and transport infrastructure. Therefore, the local plan should consider allocating land to meet purely these stated employment needs, which in turn will lead to an increase in jobs. Whilst the urban areas are likely to be the priority focus for the new local employment needs, with proposed development along the rail corridors also likely, some of this employment focus should also be towards the rural areas, helping to maintain their vitality and viability. We support the Local Plans ambition with respect to overall economic growth and believe that a housing requirement uplift is necessary to support this.
In addition, the PPG identifies other factors which need to be considered when determining the housing requirement. These include growth strategies, planning infrastructure, previous levels of delivery and recent assessments of need such as Strategic Housing Market Assessments (SHMA) where this suggests a higher need (PPG ID 2A-010) The Plan must be aspirational but deliverable to be positively prepared (NPPF, Paragraph 16), and the target of new homes per annum is insufficient to realise job-led housing need across the plan area. In order to be found sound, the Local Plan should be targeting higher growth within the Local Plan in accordance with the above explanation
In regards to spatial strategy, the previous Issues and Options consultation included six development locations/options which could form part of a strategy for growth. We responded suggesting that an amalgamation of all of the six development locations would provide a suitable strategy providing housing within the urban and rural areas. Following this consultation and the subsequent responses and other additional work around transport models, the Development Strategy Topic Paper was compiled.
The Development Strategy Topic Paper (June 2021) provides 7 options for location of growth, some of which have sub options included. These options range from development in and around the urban area only, to more dispersed development along the railway corridor and within the rural areas. From these options, emerged the preferred four options, detailed below.
The current draft Local Plan provides four emerging preferred options. All of these options seek to focus development in and around the urban area, plus along the A421 transport corridor with varying degrees of development of rail-based growth parishes, southern parishes plus the addition of one or two new settlements. Whilst the proposed four options provide a variety of figures, 1,500 dwellings are proposed to be directed to the urban area with an additional 1,500 dwellings, along with employment allocations and growth, to adjoin the urban area. All options seek to deliver at least 12,500 dwellings and up to 131 ha of employment with a minimum of
8,642 net additional jobs to be provided to 2040. It has been discussed previously how these figures should be
seen as a minimum. Whilst a larger proportion of housing and employment growth should be focused on the urban area, growth should also be located within the rural areas. In combination with the growth dispersed to the urban areas, development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. It would promote housing and would also ensure that rural areas received appropriate level of growth to maintain and enhance economic vitality, and the services and facilities required would be maintained. This approach would take account of Paragraph 79 of the Framework sufficiently to promote housing growth in the rural settlements of the Borough. In such areas, more housing would assist in maintain the vitality of the rural areas, including the retention of services and facilities that depend on economic growth. Such an approach will promote greater and more sustainable development. This is especially the case within Bedford Borough, where there may be further growth in the currently ‘rural’ areas due to the potential Oxford to Cambridge Arc.
A mix of smaller and medium scale sites 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 Councils to continuously maintain a healthy and constant supply of deliverable sites.