Bedford Borough: the Local Plan, OxCam and housing numbers

CPRE Bedfordshire has written to the Mayor of Bedford, Dave Hodgson, raising a number of issues concerned with housing numbers, government policy and the OxCam Arc.

In our response to the Local Plan 2040 Consultation (August 2021), CPRE Bedfordshire expressed serious concerns about the impact of government policy on the housing target for Bedford Borough, calculated using the government’s Standard Method algorithm. We also expressed concerns about the implications of the Oxford-Cambridge Arc Strategy and the assertion in the draft plan that the implications for housing targets in Bedford remained unknown at that time and could not be planned for.

In November 2021, BBC updated the information on the Local Plan 2040 section of their website in response to questions raised by CPRE Bedfordshire, local residents and other groups about the impact of OxCam on the Local Plan. Our view at the time was that the information seemed to leave Bedford Borough residents with more questions than answers about the implications of OxCam for Bedford.

Following on from this, our letter asks two key questions of Mayor Dave Hodgson and Bedford Borough Council.

Planning reforms and the Standard Method

In September 2021 Michael Gove was appointed Secretary of State for Levelling Up, Housing and Communities. Michael Gove has told MPs he is looking again at the way housing needs targets are calculated. Speaking in front of the housing, communities, and local government committee soon after his appointment, he said: “In making a calculation of housing need overall one of the things I wanted to do is to look at how the numbers are generated in the first place. Because I think that some of the assumptions there are probably out of date.” He also suggested that if local planning authorities believe that their housing targets, as calculated from the Standard Method were too high for their area, they could put their case to his department.

Question one

In the light of the more flexible approach signalled by the Housing Secretary, and the Council’s concern to avoid the prospect of providing significantly more houses than required to meet local need, can you please let us know what steps you have taken, or intend to take, to make the case to the Housing Secretary that Bedford’s housing target for the draft Local Plan 2040 should be revised in line with the original assessment by Opinion Research Services, rather than to maintain the earlier figure calculated through the Standard Method?

The Oxford-Cambridge Arc

It will be up to local leaders to identify the priorities they wish to support across the Arc.
Local CPREs across the Oxford-Cambridge Arc firmly believe that the decision on which growth option to utilise must be based on environmental and social constraints specific to their locality, the demands of the climate and biodiversity emergencies, and the needs and wishes of local people. They should not be based on notional Oxford-Cambridge Arc targets which have never been subjected to public consultation.

Question two

Can you please let us know whether you will be updating the Council on the latest position, and how you will identify any priorities associated with the Oxford to Cambridge Arc Strategy that you intend to put forward for Bedford, in advance of the publication of the next draft of Local Plan 2040?

It is CPRE Bedfordshire’s hope that current strategic planning for Bedford Borough through the Local Plan 2040 will not be influenced by the uncertain and untested growth objectives of the OxCam Arc.

Read the letter in full: Letter to Mayor Planning Reforms and OxCam_FINAL(PDF)

The Mayor’s response in full

Thank you for your letter of 28th March regarding the Local Plan 2040.

As you will be aware, Bedford Borough Council has previously asked the Government to look at both delaying the Local Plan process due to the very significant mis-match between the timetable for the development of the Arc Spatial Framework and that of the Local Plan Review, and also that housing land supply is calculated on a three-year requirement, as was previously agreed in Oxfordshire, rather than a five-year requirement. Bedford Borough Council believes that the Standard Method generates a target number of houses per year for the Borough which is far higher than we should have to accommodate. Indeed, the ORS work that you quote was commissioned by the Council and forms part of our Evidence Base for the forthcoming Local Plan.

Bedford Borough Council has also pressed the Government numerous times about the national standard method and I have recently written to the Secretary of State to ask for a review of both the concept of the national standard method for determining housing targets, and of our own target in particular. However, as you may be aware, the latest update (March 2022) to the standard method calculations have increased our target again. Bedford Borough Council believes that a more realistic housing target would be 1,021 dwellings per annum as per the original assessment by ORS. I will therefore be contacting the Secretary of State again on this matter.

The Council has today published the Local Plan 2040 Report which will go to the Executive on 27th April and you can find a copy here.

In the meantime, we do have to plan for the target we have been given. If we do not plan to achieve it, we run a grave risk of our plan being found “unsound” at Examination, meaning that there would follow a development “free for all” in the Borough with no proper planning of either the location of growth or the infrastructure that needs to be in place to mitigate its impact. That is not a risk that we are prepared to take, and I am sure you agree is something we should work together to avoid.

For clarity, I would confirm that we are not planning for any additional growth, whether related to the Arc or otherwise, on top of that mandated by the standard method and more broadly, I will continue to update Council periodically regarding the Ox-Cam Arc.

The CPRE Bedfordshire view

CPRE Bedfordshire are in favour of a democratic plan-based planning system. We appreciate that the Council are obliged to submit local plans according to the requirements of the Planning Inspectorate. It’s positive that the Council has a good track record in maintaining an up to date local plan and making planning decisions that are generally consistent with the agreed local plan.

One of the key elements of a local plan is the housing needs target which is identified through a housing needs assessment but if the housing needs target is not justified, realistic and is unreasonably high, then the whole purpose of the local plan is undermined.

We are therefore pleased to see that the Mayor agrees with us about the unnecessarily high housing numbers being imposed on Bedford Borough via the standard method calculation, and that Bedford Borough Council have been making representations to the Secretary of State. However, more detail about the case put by the BBC to the Secretary of State and any response received would be welcome.

We also feel that there are unanswered questions about OxCam, in particular about paragraph 1.17 of the latest draft Local Plan which states:

‘Where housing growth is concerned, as a result of existing commitments (including those made and to be made in neighbourhood plans) and new allocations made in this plan, the Council will make provision for significantly more homes as described in the Arc joint declaration. It will do this as a result of government’s new standard method for calculating housing need, which it will deliver in full, and which results in an uplift of 40% when compared to the locally-calculated housing growth planned for in the Local Plan 2030, and by allocating sites that will continue to build out beyond the 2040 plan end date.’

This seems to suggest that the Council is proposing to provide significantly greater levels of housing in order to meet the Arc aspirations for accelerated growth and that this comes through the application of the standard method. This looks like it is confirming our worst fears that having distanced itself from the one million homes target the government is aiming to achieve ‘OxCam by Stealth’ through the standard method. We will be asking the Mayor whether he feels that this a correct interpretation of paragraph 1.17.

We appreciate the Mayor taking the time to respond to our letter and we look forward to continuing the conversation on the areas where we would like to see greater clarity.