You may be aware that the Government has issued a technical consultation on updates to national planning policy (in the National Planning Policy Framework) and guidance (in the National Planning Practice Guidance). The consultation document can be found here https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/751810/LHN_Consultation.pdf

Comments must be submitted by 23.45 on Friday 7th December.

The proposals could have an impact for all local councils, but particularly if you are preparing a neighbourhood plan. This email explains a bit about the consultation and why you should consider submitting a response.

The consultation seeks views on changes to planning practice guidance relating to the standard method for assessing local housing need and policy clarifications relating to housing land supply, the definition of deliverable and appropriate assessment.

It is particularly relevant to Bedford Borough because if introduced, the proposed change to the calculation of housing supply would significantly reduce the number of years’ housing land that we have available. At present the Council can show a healthy 5.8 years of housing land supply. The consultation document proposes that for the determination of planning applications (so not for local plan purposes which are covered by transitional arrangements which allow us to keep our own locally based calculations) the new standard method for calculating housing need must be used immediately. In those circumstances we would have around 3.5 years of supply – below the 5 years’ worth that is required which would mean that less weight could be given to our own Bedford Borough adopted planning policies when planning applications are determined. It is thought that the Government will make proposed changes to policy and guidance in January 2019 so this is when the current position on the supply of housing land would change.

This may result in the submission of speculative applications around the Borough from those seeking to take advantage of the new position. In particular, it may result in planning applications on sites that are currently being considered by neighbourhood plan groups (supported or unsupported in neighbourhood plans), forcing a decision on suitability before neighbourhood plans are made.

Along with other Councils who are benefiting from the transitional arrangements for plan-making we had interpreted the 2018 update of the National Planning Policy Framework to mean that those arrangements also applied to the determination of planning applications; it seems illogical to have two completely different scenarios running concurrently. However, the consultation clarifies that it is not the Government’s intention that the transitional arrangements should apply across the board.

Perversely, once the local plan is adopted the lower number in the local plan will be re-instated as the basis for calculating land supply which would take us above 5 years once again. This adds to the lack of common sense in what the Government is intending to do.  Our intention is to submit the Local Plan 2030 to the Planning Inspectorate during December 2018. The published timetable anticipates that if there are no major delays, adoption of the plan should take place in the autumn of 2019, which means that there would be about a 9 or 10 month period where there could be significant development pressure.

It is important that what are possibly unintended consequences associated with these proposals are brought to the Government’s attention. The Borough Council’s response to the consultation has now been approved and is attached to this email. It may help you to submit your own response using this link https://surveymonkey.co.uk/r/technicalplanningconsultation

If you are preparing a neighbourhood plan, I would urge you to make strong representation about the potential impact that the proposal to bring in the standard method as a basis for calculating land supply for the determination of planning applications could have on your community and the damaging effect it could have on your neighbourhood plan making, which in many cases has been on-going for a number of years.

As mentioned above, the closing date for comments is 7th December 2018.

Kind regards,

Kim Wilson

Team Leader – Planning Policy

Bedford Borough Council