3 Spatial Strategy Policy SP1: Growth Strategy Section 1.4: Calculating Housing Need Sections 1.5 & 5.5: Partial Plan Review Section 1.7: Requirements of Plan Making Section 5.2: Key Spatial Objectives Section 5.4: Spatial Strategy Approach Section 6: The Proposed Locations for Growth Section 12.8: Education and Skills Introduction 1. This representation has been made on behalf of Abbey Land Developments Limited to the Regulation 19 pre-submission draft of the Central Bedfordshire Council (CBC) Local Plan 2015 – 2035. Summary of Representation 2. This representation highlights the failure of the Draft Plan to deliver the amount of overall housing required to meet current needs and, in particular, its failure to adequately provide for Luton’s unmet housing and educational needs in appropriate locations, and in a timely manner. 3. This representation also objects to the failure of the Draft Plan to expressly identify West of Luton as a housing allocation from the outset, and to instead consider its possible allocation as part of a future Local Plan Review. We also object to its site capacity being identified as 2,000 dwellings. We consider that the location supports the allocation of 4,600 dwellings (3,500 dwellings as a new allocation, and 1,100 dwellings in respect of Safeguarded Land to be released via the Partial Local Plan Review). Policy SP1: Growth Strategy and Spatial Strategy Approach (Section 5.4) 4. We have submitted a separate and more detailed representation in relation to the failure of Policy SP1 to identify West of Luton as an immediate Local Plan allocation, and to instead rely upon a future Partial Local Plan Review to do this (as detailed in paragraph 5.5 of the Draft Plan). 5. Separate representations have also been submitted with regard to other matters; including the content of the Draft Plan’s Vision and Objectives and the Sustainability Appraisal. 6. In addressing serious deficiencies in the overall Spatial Strategy, our representation draws heavily upon the findings of two particular documents. Firstly, the Central Bedfordshire Pre-submission Local Plan: Review of Housing Need and Land Supply prepared by Lichfields (seeAppendix 3.1). This Report has been jointly commissioned by Abbey Land Developments Ltd, Richborough Estates, Catesby Estates, and Rainier Developments Ltd. Secondly, we refer extensively to the content of Luton Borough Council (LBC)’s Schedule of Draft Representations to the Draft Plan as reported to its Executive Meeting on 20 February 2018 (see Appendix F of Appendix 3.2). We quote in brackets the relevant paragraph numbers of the reports. Central Bedfordshire Local Plan Submission Draft (Regulation 19) 23 Representations on behalf of Abbey Land Developments Ltd Section 1.4: Calculating Housing Need 7. The Central Bedfordshire Pre-Submission Local Plan sets out at Policy SP1: Growth Strategy that 39,350 homes will be delivered in Central Bedfordshire over the period 2015 to 2035. This includes the 32,000 of objectively assessed housing needs (“OAHN”) for Central Bedfordshire, and a commitment to facilitate 7,350 of Luton’s unmet need – subject to ongoing duty to co-operate discussions and formal Local Plan Examination. The Plan makes provision for the delivery of a total of 41,830 homes over the plan period, of which c.23,000 are existing commitments, and c.18,000 are a combination of strategic (c.9,900) and small – medium scale (5,505) allocations throughout Central Bedfordshire. Luton and Central Bedfordshire SHMA (2015) 8. The Luton Local Plan was underpinned by an iteration of the Luton and Central Bedfordshire SHMA published in 2015 (“the 2015 SHMA”), which concluded that OAHN for Luton was 17,800 dwellings over the period 2011-31 (equivalent to 890 dwellings per annum). The 2015 SHMA used 10-year migration trends (from the 2001-11 period) and concluded that a market signals uplift of 10% overall was appropriate for the Luton and Central Bedfordshire HMA; it apportioned a 20% uplift to Luton and 5% to Central Bedfordshire (2015 SHMA para 4.105). 9. The Lichfields Report has concluded The Council should not – as at is has done - take the Luton Local Plan Inspector’s report as a direct endorsement of the SHMA, not least because the SHMA tested at the Luton Local Plan Examination has now been superseded (2.13). 10. In addition, the Inspector noted numerous reasons why the OAHN (for either Luton or both Luton and Central Bedfordshire) may be “potentially higher” (IR 97): 11. The Inspector identified Luton’s capacity for housing (over the 2011-31 period) to be 8,500, leaving (against a figure of 17,800) an unmet need of 9,300 dwellings to bet met elsewhere (IR 138). The emerging North Hertfordshire Local Plan makes provision for some of this need (1,950 dwellings) (IR 14), with the remaining likely to fall to Central Bedfordshire. The Inspector noted that Aylesbury Vale is unlikely to be a ‘prime candidate’ to receive any significant quantity of Luton’s unmet needs’ (IR 141), and the emerging Vale of Aylesbury Plan does not make any provision for this. 24 Central Bedfordshire Local Plan Submission Draft (Regulation 19) Representations on behalf of Abbey Land Developments Ltd Review of Luton & Central Bedfordshire Strategic Housing Market Assessment (2017) 12. Since the Luton Local Plan Examination, a 2017 SHMA has been prepared. It takes into account more recent data, including the 2014-based household projections and mid-year population estimates up to 2015/16. It concludes that OAHN for Central Bedfordshire is 31,778 dwellings 2015-35, or 1,589 per annum. For Luton it concludes on OAHN of 18,810 dwellings 2015-35, or 940 dwellings per annum (ie c.1,000 more than the OAHN that underpinned the adopted Luton Plan). This equates to a total of 2,529 dpa for the two authorities. 13. Over the 20 year period, the household projections therefore project overall growth of 34,580 households. By contrast, the SHMA’s concluded OAHN for Central Bedfordshire (which purports to take into account employment, market signals and affordable housing needs) is less than this, at 31,778. In other words the SHMA concludes that OAHN is less than what the PPG itself defines as the ‘starting point’. Given the PPG (ID2a-017) is clear that the official projections should be regarded as “statistically robust and are based on nationally consistent assumptions” Lichfields has stated that this immediately raises concerns as whether the adjustments made by the SHMA are reasonable and robust, particularly given Figure 35 of SHMA shows population growth in Central Bedfordshire has been increasing over time (2.22). 14. Lichfields have found that the SHMA’s adjustments to ONS’s official projections are not based on established sources of robust evidence and therefore do not meet the PPG requirements for departing from the official projections (2.27). Indeed, they point out that other ONS data on the margins of error around the MYEs shows Central Bedfordshire is within the top 25% LPAs in England in terms of accuracy, i.e. the MYEs for Central Bedfordshire are considered by ONS to be amongst the most accurate (i.e. having a small margin of error) in England (2.28). 15. In light of the above analysis, Lichfields state that there is a case to be made that at the very least, the market signals uplift for Central Bedfordshire should be at minimum 20%. Taking a demographic-led baseline of 1,800 dpa based on the latest projections, this would equate to c.2,150 dwellings per annum. Analysis of stock growth rates elsewhere shows this is in line with the level seen in Cherwell, and like Central Bedfordshire, Cherwell will need to accommodate additional unmet needs from its neighbour (in Cherwell’s case, from Oxford). OBR modelling suggests that an uplift even greater than this may be needed to improve affordability, however in light of stock growth elsewhere and the outcomes of method (3), a minimum of 20% is considered appropriate (2.52). 16. Lichfield have criticised the failure of the SHMA to adequately meet the PPG requirement to set its uplift at a level that is related to the problems of affordability or that could be expected to improve affordability; indeed, the SHMA fails to approach this question at all (2.53). Central Bedfordshire Local Plan Submission Draft (Regulation 19) 25 Representations on behalf of Abbey Land Developments Ltd Housing Market Area and Duty to Co-operate 17. A Joint Growth Options Study (JGOS) was prepared by LUC consultants on behalf of Luton Borough Council, Central Bedfordshire Council, North Hertfordshire District Council and Aylesbury Vale District Council. The aim of the JGOS was to identify and assess at a high level how Luton’s FOAN could be delivered within Luton’s administrative area and the wider HMA. Subsequently, the NHDC and LBC Statement of Common Ground (“SoCG”) Addendum (October 2017) states that the conclusions of the JGOS study are agreed by all four authorities (LBC, CBC, NHDC and AVDC). 18. Lichfields have pointed point that the 2017 SHMA has updated Luton’s OAHN to a new higher figure of 18,810 , and assuming Luton’s capacity remains unchanged this will increase the level of unmet need to be met elsewhere (by c.1,000). A very small part of Luton’s FHMA falls within Aylesbury Vale, however Aylesbury Vale has not indicated any plans to meet Luton’s unmet need (and the District also faces considerable pressure from within the Buckinghamshire HMA). A further small part of Luton’s FHMA falls within North Hertfordshire District, which has indicated that it will meet 1,950 of Luton’s unmet need in its emerging Plan.