Central Bedfordshire & Luton Strategic Housing Market Assessment (SHMA) (Dec 2017)

Showing comments and forms 1 to 11 of 11

Object

Technical Reports

Representation ID: 8374

Received: 18/02/2018

Respondent: CPRE Bedfordshire

Representation:

METHODOLOGY - Challenges to Council OAN; OAN overstates housing need

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CPRE Bedfordshire believes that the estimate of Housing Need established by the SHMA is incorrect.
There is insufficient capacity in this box (max 100 words) to explain our reasoning in detail.

Please refer to CPRE Bedfordshire's detailed response to the Pre-Submission Local Plan Consultation which has been uploaded as part of this submission. Please see Section6 on pages 9 & 10.

Object

Technical Reports

Representation ID: 8449

Received: 18/02/2018

Respondent: CPRE Bedfordshire

Representation:

METHODOLOGY - Challenges to Council OAN; OAN overstates housing need

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CPRE Bedfordshir does not believe that the Housing Need Assessment as part of the SHMA is correct.
There is insufficient space in the box (Max 100 words) to detail our concerns.

Please go to CPRE Bedfordshire's response to CBC's Pre- Submission Local Plan Consultation which hsa been upoaded with this submission.

Please refer to Section 6, pages 9 and 10 for more details of our objection.

Object

Technical Reports

Representation ID: 9681

Received: 22/02/2018

Respondent: The Crown Estate

Agent: Savills

Representation:

METHODOLOGY - Challenges to Council OAN; alternative OAN proposed

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3.59. The Council's SHMA states that the objectively assessed housing need for Central Bedfordshire equates to 32,000 dwellings within Central Bedfordshire in the plan period 2015 to 2035. To this the draft Local Plan adds the 7,350 dwellings of unmet need resulting from Luton being unable to meet all of its identified need within its administrative boundaries.
3.60. However, the approach to meeting objectively assessed housing needs as set out in the NPPF (paragraph 47) is one where (our emphasis) "local planning authorities should ... use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area". Any 'OAN' identified for Central Bedfordshire as a local authority area has to be viewed in the context of the four constituent HMAs (Milton Keynes, Bedford, Stevenage and Luton) - the approach taken to meeting the unmet need from any one HMA should be the same approach as taken to meeting that part of the identified need for the HMA that falls within Central Bedfordshire.
3.61. Hence, to state the 'OAN' as 32,000 is incorrect - more correctly, and notwithstanding our concerns in this regard, this should be stated as the proposed housing requirement for Central Bedfordshire; however, even that is incorrect as it omits the unmet need that is proposed to be met from Luton.
3.62. In this regard, with respect to the boundaries of the area covered by the SHMA, it is worthy of note that the SHMA itself comments (paragraphs 2.88 and 2.89):
"However, it is important to recognise that this "best fit" (of Luton and Central Bedfordshire as an HMA) does not change the actual geography of the functional housing market areas that have been identified - it simply provides a pragmatic arrangement for the purposes of establishing the evidence required and developing local policies, as suggested by the CLG advice note and reaffirmed by the PAS technical advice note.
Whilst we have concluded that Luton borough and Central Bedfordshire provide the overall "best fit" for the functional housing market area on the basis of all of the available evidence, the more important issue is the need for both authorities to maintain dialogue with Milton Keynes, Bedford, North Hertfordshire, St Albans, Hemel Hempstead and Aylesbury Vale, and other local authorities in the surrounding area, as well as with the Mayor of London through the Greater London Authority."
3.63. As we have commented previously in our representations, as yet the Council has published no evidence that such suitable dialogue has been maintained, or the requirements of the Duty-to-Cooperate fulfilled.
3.64. Savills has analysed how the Council has arrived at the stated OAN of 32,000. This analysis is attached at Appendix 1 to these representations, which was submitted to the 2017 consultation on the Draft Plan for Central Bedfordshire. The analysis concludes that the Council has considerably underplayed the additional number of required new dwellings that will arise from migration into Central Bedfordshire and from the uplift that should be applied to account for market signals (i.e. (un)affordability). To a lesser, but nevertheless significant degree, we consider that the Council has also underplayed its assumptions concerning conversion to dwellings and household formation rates. As a result of this analysis, we consider that the objectively assessed housing need for Central Bedfordshire should be 2,164 dwellings per annum. This equates to 43,280 dwellings in the plan period 2015 to 2035.
3.65. Accounting for meeting unmet housing need from Luton (7,350 dwellings), which we support, we consider that the housing requirement for Central Bedfordshire should be 50,630 (43,280 + 7,350), 12,080 more than provided for in the draft Plan.
3.66. As discussed previously in these representations, although the Government's proposed standard method of calculating housing need is likely to increase significantly the 'OAN' from the 1,600 dpa proposed in the current consultation to c. 2,440 in Central Bedfordshire alone (i.e. excluding Luton and any other surrounding authority areas), including a sizeable uplift to address matters of (un)affordability. Notwithstanding any need for Central Bedfordshire to address increased housing requirements in Luton or other surrounding local authority areas, the housing requirement on this basis for Central Bedfordshire would be some 50,000 dwellings.
3.67. A failure to facilitate the true level of growth required to address current, existing, matters of (un)affordability will only serve to exacerbate the issue.

Object

Technical Reports

Representation ID: 9799

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

METHODOLOGY - Challenges to Council OAN; justification for recalculating migration flows weak; market signals adjustment of 10% inadequate, suggest 30%; conversion to dwellings; and household formation rates too low

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See attached representation.

Attachments:

Object

Technical Reports

Representation ID: 11920

Received: 22/02/2018

Respondent: Hearne Holmes Developments Ltd

Agent: DLP Planning Limited

Representation:

METHODOLOGY - Challenges to Council OAN; no regard to new standardised methodology; justification for recalculating migration flows weak; market signals adjustment of 10% inadequate

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Please see full attached representation

Comment

Technical Reports

Representation ID: 12296

Received: 22/02/2018

Respondent: Gladman Developments Limited

Representation:

METHODOLOGY - Challenges to Council OAN, alternative methodology/evidence proposed

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Full text:

see attachments

Attachments:

Comment

Technical Reports

Representation ID: 12366

Received: 22/02/2018

Respondent: Denison Investments

Agent: Arrow Planning

Representation:

METHODOLOGY - Challenge assumptions underpinning calculation of OAN; Partial Plan review should re-asses OAN using new standardised approach

04

Full text:

see attachment

Attachments:

Comment

Technical Reports

Representation ID: 12971

Received: 22/02/2018

Respondent: Richborough Estates

Agent: RPS Planning and Development

Representation:

see comments on OAN

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 13262

Received: 22/02/2018

Respondent: Pigeon Land Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

TARGETS - Needs has not been properly assessed
STRATEGY - Luton's need is not properly assessed
DTC - Will fail DtC obligations

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Full text:

See attachment

Attachments:

Object

Technical Reports

Representation ID: 13374

Received: 22/02/2018

Respondent: Abbey Land

Agent: JB Planning

Representation:

GENERAL - attachment refers to SHMA, but no specific critique made

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See attachments and appendices 4.1-4.5 attached to the Representation on Policy SP1

Representations created for the following documents:
Legal Soundness/Duty to Co-operate - Ch. 1.7, 1.10, 6,2
Vision and Objectives - Ch. 4.2
Spatial Strategy/Policy SP1 - Ch. 1.4, 1.5, 1.7, 5.2, 5.4, 6.0, SP1, 12.8
Monitoring - Ch. 7.3
Key Diagram - Ch. 7.4
Policy SA1 - Ch. 7.7, SA1
Policy HA1 - Ch. 7.8, HA1
Green Belt/Policy SP4 - Ch. 8.0, SP4
Sustainability Appraisal

Comment

Technical Reports

Representation ID: 13878

Received: 22/02/2018

Respondent: Catesby Estates Plc

Agent: Mr Simon Atha

Representation:

METHODOLOGY - concerns over assumptions made with regards to delivery and 5 year supply shortfall

Full text:

See attachments

Attachments: