Central Bedfordshire Pre-submission Local Plan (January 2018)

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Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

5. The Spatial Strategy

Representation ID: 11807

Received: 22/02/2018

Respondent: Northern Trust

Agent: Maddox Associates

Representation:

TARGETS - Council should review Plan housing target in line with standardised methodology for calculating housing need, which demonstrates that Central Bedfordshire has a significantly greater need than currently planned for

04

Full text:

We are writing on behalf of our client, Northern Trust, in response to the consultation on the presubmission
version of the emerging Local Plan.
We support the overall strategy of the Plan and support the Council's efforts being undertaken to ensure
an up-to-date local plan is in place. Our response to the consultation is provided below.
Housing need and plan target
We support the Council's acknowledgement within the Local Plan that it needs to increase the number
of homes built in Central Bedfordshire. The Central Bedfordshire Strategic Housing Market Assessment
sets out that 32,000 dwellings are required in the new plan period of 2015-2035, which equates to
1,684 dwellings per annum. We subsequently concur that that the Council should be, as a minimum,
meeting its Objectively Assessed Need for housing of 1,684 dwellings per annum for the period between
2013-20136.
However, as the Council correctly acknowledges within the Draft Local Plan, the Government published
a new standardised methodology for calculating housing need in September 2017. This standardised
methodology sets out that Central Bedfordshire should be delivering 2,553 dwellings per annum. This is
a significant increase above the existing OAN set out above and has not been considered by the Council
in the Draft Local Plan. This is especially pertinent given that the Council acknowledges that the 'OAN is
likely to rise over time.'
We are therefore of the view that the Council should review its housing need and plan target in light of
the Government's standardised methodology for calculating housing need, which clearly highlights that
the Council should be planning for a far greater number of housing than what it currently proposes.
Following its revision of the Local Plan housing target to correlate with the Government's standardised
methodology, it is important that the Council identifies further land through the Local Plan process to
facilitate this greater growth.
Growth strategy
We support in principle the Council's growth strategy as set out within the Draft Local Plan. We agree
that the Council should be allocating a number of sites throughout Central Bedfordshire to
accommodate the growth required up to 2035, including on land currently designated as Green Belt.
Furthermore, we fully support the Council's acknowledgement that Green Belt boundaries will be
redrawn where a strong case can be made that they meet the exceptional criteria, as defined in the
National Planning Policy Framework (NPPF).
To assist with the growth strategy, we fully support the proposals to create one new village to the east of
Biggleswade, four new villages in Marston Moretaine, a new extension to the north of Luton; a new
extension to the east of Arlesey and small to medium growth in existing towns and villages. However, as
set out above, the Council should identify further locations for growth to accommodate the additional
housing need identified through Government's consultation on a standardised methodology for housing
need.
Affordable housing
The Council's intention to require 30% affordable housing on schemes of 11 units or more or 10 units or
less which have a combined grossed internal floor space of 1,000 sqm is supported. We also support
the reference to viability testing within draft Policy H4, which sets out that 'where policy compliant
affordable housing cannot be achieved, viability will determine affordable housing provision on a case by
case basis'.
Summary
In summary, we support the preparation of the Local Plan. We also support the proposed growth
strategy and the provision of new villages and urban extensions to accommodate the forecasted growth
and also, commend the Council in acknowledging that it will need to consider the release of green belt
land to enable the further growth. However, we consider that the Council should review its local plan
housing target in line with the Government's standardised methodology for calculating housing need,
which demonstrates that Central Bedfordshire has a significantly greater need than currently planned for.
This will subsequently result in a requirement for the Council to identify further land through the Local
Plan process to accommodate this additional growth.
Thank you for the opportunity to respond the Local Plan pre-submission consultation. We hope these
comments are of assistance and would be grateful for confirmation that they have been considered as
part of this consultation. We confirm that we would like to be involved in the future stages of the local
plan preparation.

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