Object

Representation ID: 10003

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

6. POLICY DS3 - AMOUNT AND TIMING OF HOUSING GROWTH
6.1 Wates objects to the proposed stepped trajectory, as set out at Policy DS3. This draft policy identifies an overall housing requirement of 27,100 new dwellings, to be delivered during the Plan-period, as follows;
• 2020/21 to 2024/25 – 4,850 dwellings (970 dpa)
• 2025/26 to 2029/30 – 5,250 dwellings (1,050 dpa5)
• 2030/31 to 2039/40 – 17,000 (1,700 dpa)
6.2 It is then explained that the ‘five-year housing land supply’ (‘5YHLS’) position, as an ongoing calculation, will then be measured against the stepped requirement above, as applicable at the time of assessment.
Principle of the Stepped Trajectory
6.3 Wates understands why BBC argues for a stepped trajectory in the context of this Plan. The Council’s case is set out in the Draft Plan at pages 27 and 28 (and in the supporting evidence base reports), and references the Government’s specific advice relating to stepped trajectories in the Planning Practice Guidance (PPG)6. This indicates that: “A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period.”
6.4 Certainly, Wates recognises that the Local Housing Need (LHN) figure of 1,355 dpa (as identified through the Standard Method), is approximately 40% higher than the annual requirement in the recently adopted Local Plan 2023 (970 dpa). Noting the particular circumstances of the early review, this uplift may also point to a potential justification for a stepped trajectory.
6.5 Likewise, as indicated in our comments of Policy DS2, the Draft Local Plan’s spatial strategy is partly predicated on the delivery of strategic-scale development and new rail-centric growth, which is associated with significant infrastructure dependencies. This is set out in the evidence base report ‘The Need for a Stepped Trajectory: Transport’ (AECOM 2022), which confirms that significant improvements to the A421 and A428 ‘Black Cat to Caxton Gibbet’ are required to increase network capacity. These works are not expected to commence before 2025. Similarly, East West Rail (to Cambridge) is currently identified for completion in 2030. The infrastructure requirements associated with key parts of the proposed spatial strategy do therefore lend support for a stepped trajectory.
6.6 However, whilst the circumstances of this Plan may justify the consideration of a stepped trajectory ‘in-principle’, the NPPF (at paragraphs 22, 60 and 61) is equally clear that housing needs should be met fully and without delay. Likewise, Section 5 of the NPPF places an overall emphasis on timely delivery. It is also relevant that the PPG7, in advising on potential stepped trajectory arrangements, also specifically stipulates that;
“…planned housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs.”
6.7 BBC is therefore obligated to fully explore all opportunities for achieving earlier delivery, before concluding that a stepped trajectory is necessary and justified. Wates, having reviewed the trajectory presented in the evidence base document ‘Stepped Trajectory Topic Paper (April 2022)’ does not agree that all such opportunities have been exhausted.
6.8 It must also be remarked that BBC’s most recent five-year housing land supply position statement (‘5 Year Supply of Deliverable Housing Sites, 2021/22 – 2025/26’, dated August 2021) identifies a claimed supply of 6.56 years, against an annualised requirement of 739 dwellings (with this reduced 5YHLS requirement reflecting an accrued over-provision of 1,333 dwellings). This is a relatively strong supply position.
6.9 Furthermore, over the 6-year period 2015/16 to 2020/21 a total of 7,153 completions were achieved in the Bedford Borough, equating to 1,192 dpa and significantly exceeding the identified 5-year requirement of 4,850 dwellings. The Borough does not therefore appear to have a track-record of poor delivery, at least in recent years.
6.10 Therefore, Wates objects to the stepped trajectory as proposed and does not consider it to be justified by the evidence at this time. Wates invites BBC to review the comments and analysis below, and consider the proposed alternative stepped trajectory presented on page 19 of these representations.

Opportunities to Facilitate Earlier Delivery
6.11 On review of the Draft Local Plan, there appears to be potential to facilitate earlier delivery through amendments to proposed policy requirements. In this way, timely delivery could be supported within the overall framework of the proposed vision and spatial strategy, and suite of allocations that are proposed in the Draft Plan.
6.12 For example, Policy HOU12 implies that no new development within the South of Bedford area can come forward until a ‘strategic place making framework’ has been prepared by BBC. This approach appears to represent a significant impediment to development and Wates is not clear as to why this is needed or what additional benefits will be achieved, when compared to (for example) simply requiring allocations, particularly some of the clearly standalone allocations, to be supported by individual masterplans, visions or site-specific SPDs (where their size justifies this8). Indeed, this is the approach that is taken to most of the allocations proposed outside of South of Bedford area.
6.13 Regardless, and owing to very wide geographic extent of the South of Bedford policy area, it seems likely that the envisaged strategic framework will take some time to be progressed and concluded. That is a particular concern when, consistent with BBC ‘Statement of Community Involvement’ (2019), there will be a requirement for community and stakeholder engagement and input, which will be challenging to coordinate in a timely manner.
6.14 Therefore, and as we detail more fully in Section 6 of these representations, Wates consider that Policy HOU12 and its supporting text should be modified to promote a more targeted approach. Indeed, some of the proposed allocations within the South of Bedford area clearly have the potential to be developed sustainably, without any obvious need for them to refer to the invariably high-level policies and/or guidance, which might be expected to be contained within the future strategic place making framework.
6.15 For example, Land South of Wixams (HOU15) is not directly dependent on the provision of new strategic-scale infrastructure9. The allocation is also essentially proposed as a self-contained expansion to Wixams, a new settlement where the pattern of development is well-established and understood, and where there are established cross-boundary processes for considering development proposals. Likewise, the allocation proposed at Policy HOU18, the former DVSA site at Shortstown (a site which Wates has no involvement with) appears to be similarly self-contained, such that it would seem to be capable of being brought forward in timely way. Therefore, it is not clear why these allocations should be prevented from coming forward before the encompassing ‘strategic place making framework’ is prepared and adopted.
6.16 Wates and Boyer would also add that, based on our recent experience of participating in Local Plan Examinations across the country, the Inspector for the future Examination of the Bedford Local Plan 2040 is likely to require the Plan to be modified so as to clearly specify the minimum quantum of development to be achieved at each allocation. In support of this, we strongly recommend that BBC engages with all of the relevant promoters / developers and seeks to confirm the level of development expected to be brough forward and when, and (where possible) conclude statements of common ground. Wates have this information and have provided it to BBC in relation to Land South of Wixams.
Overly Cautious Trajectory
6.17 A further concern is that the trajectory presented in the ‘Stepped Trajectory Topic Paper’ (April 2022) appears to be excessively cautious in its estimations of housing delivery, across various sources of supply. This includes the allocations proposed in the Draft Local Plan, but also existing commitments and sites allocated within the Local Plan 2030.
6.18 Whilst Wates understands why BBC would rightly want to safeguard against over-optimism, some aspects of the identified trajectory are cautious to the extent that they understate what might reasonably be expected to be achieved. This is relevant, as the trajectory presented in this Topic Paper is cited as a key justification in support of the suggested stepped requirement.
Local Plan 2040 Proposed Allocations
6.19 The Draft Local Plan proposes to allocate a number of sites, from small to medium-sized sites within the existing Bedford urban area, to larger / strategic-scale planned developments. However, the trajectory generally assumes that these sites will come forward slowly and will not provide first completions until 2030/31. As noted below, Wates considers that these timelines are, in some instances, overly pessimistic.
6.20 The Draft Local Plan, at Policy HOU1, proposes to allocate Land at Greyfriars North for the development of around 100 (net) dwellings. This allocation essentially constitutes an extension to the wider Greyfriars and Midland Road regeneration / redevelopment strategy, as set out in Local Plan 2030 (Policy 11). Wates concurs that the successful masterplanning and delivery of urban regeneration projects can take time. However, to assume no completions before 2030/31 appears excessively cautious for a site within the urban area, where the principle of redevelopment is not in question. Certainly, the Call for Site’s form (ID 1246), as completed by the site’s promoter, appears to anticipate first completions much sooner (from 2024).
6.21 Policy HOU2 identified Land at Mayes Yard, between High Street and Silver Street Bedford, for a mixed-use development. This is expected to include around 115 dwellings. Again, whilst Wates acknowledges that schemes of this nature can take some time to bring forward, to assume no delivery before 2030/31 appears as a very cautious position. This is noting that the site has been confirmed as being available for development in the HELAA Appendix 5, (additional sites assessments).
6.22 Policy HO3 proposed the redevelopment of the former Camford Works and Technology House on Ampthill Road, Bedford. BBC’s trajectory suggests around 530 dwellings will be achieved through this development, with first completions taking place in 2030. The ‘Bedford Infrastructure Delivery Plan: The Need for a Stepped Trajectory: Transport Final Report’ (AECOM, 2022), indicates that this site is not directly dependent on new strategic infrastructure provision for its delivery. There would therefore, appear be opportunities for this site to provide first completions much earlier than 2030/31. Indeed, the information provided by the site promoter (as detailed on Call for Sites form ID 505) anticipates completions within the period 2024/25 to 2028/29.
6.23 Policy HOU4, proposes to allocate the Former Peacocks auction house (Newnham Street, Bedford) for approximately 40 dwellings, following the redevelopment of this existing commercial site. The trajectory assumes first completions will take place in 2026/27. Given this site lies within the urban area and is not reliant on new infrastructure, it is not clear why its redevelopment should be so delayed. Certainly, the site promoter information (set out in Call for Sites form ID 505) suggests redevelopment would commence by the end of 2023/24.
6.24 Policy HOU5 proposes the allocation of Land at Abbey Field, to the west of Elstow, with the trajectory expecting around 200 dwellings to be delivered at this site. The trajectory expects first completions to take place in 2030/31. However, the site is not identified (in the ‘Bedford Infrastructure Delivery Plan: The Need for a Stepped Trajectory: Transport Final Report’ or the Draft Local Plan) as requiring pre-requisite strategic infrastructure improvements. It is therefore not clear why this allocation is expected to come froward so slowly. Certainly, the site promoter (in ID 638) has indicated that development could start as soon as 2025.
6.25 Policy HOU8 identifies an allocation to the west of Policy HQ, Woburn Road and anticipates the delivery of around 100 dwellings at this site. First completions are expected in 2025/26. This is probably a reasonable assessment, noting that the site (within the urban areas) appears to be relatively unconstrained and capable of bring brough forward. It is not clear then why other comparable sites are viewed more pessimistically.
6.26 Policies HOU6, HOU7, HOU9 and HOU10 propose the allocation of a number of small sites, within the Bedford urban area. These sites all appear to have the potential to come forward relatively more quickly than has been assumed by BBC.
6.27 HOU13 proposes an allocation at Gibraltar Corner, which BBC expects will deliver around 500 homes. The aforementioned AECOM Report does not indicate that the delivery of this allocation is contingent on major strategic infrastructure programmes. There would also appear to be logical potential for phasing, to facilitate early delivery. Consequently, Wates expect that completions at this site could be achieved sooner that 2027/28, as identified in BBC’s trajectory.
6.28 Policy HOU18 proposes the allocation of Land at the former DVSA site at Shortstown, with the trajectory anticipating that approximately 150 dwellings may be provided there. BBC anticipates first completions in 2030/31. This assumption appears pessimistic, as the site does not appear to be heavily constrained. Certainly, the site has been confirmed as being available for development in the HELAA Appendix 5, (additional sites assessments).
6.29 As noted in our preceding remarks, Policy HOU15 proposes to allocate Land South of Wixams. This site is under Wates’ control and the BBC trajectory assumes that only 300 dwellings will be achieved. However, as detailed in Section 7 of these representations, Wates consider the capacity to be significantly greater, at 430 dwellings. We also expect first completions to be achieved in 2025/26, as the site is not reliant on new strategic infrastructure and noting that it is a comparatively modest extension to the existing settlement.
6.30 Table 1 overleaf presents Boyer’s updated assessment of the allocations proposed in the Draft Local Plan 2040.
SEE ATTACHMENT FOR TABLE

Existing Commitments ‘Approved Subject to S106’
6.31 BBC’s trajectory also appears to have applied very cautious assumptions to sites that fall under the category ‘Approved Subject to S106’. For example, the Former Hazlewood Foods site (Dallas Road, Bedford) now benefits from full planning permission for 341 dwellings (granted April 2021). Yet, the trajectory suggests completions at this site are not expected until 2026/27. It is not clear why the site which is prima facia deliverable (as per the NPPF definition), is instead regarded as only developable.
6.32 Likewise, ref. 18/03158 granted full planning permission (on 06 April 2022) for the development of Phase 2 of the Wixams Retirement Village (on Land North of The Causeway), incorporating 62 dwellings. Yet, the trajectory suggests that first completions will not be achieved until 2028/29. This appears to be overly pessimistic, given the flatted nature of the development (which is an extension to an existing built out site) and noting that commencement would have to occur before 06 April 2025 (i.e., within three years of the decision).
6.33 Similarly, the current planning application seeking the redevelopment of the Aspects Leisure Park, Newnham Avenue, Bedford (ref. 19/01624/MAF), appears to be well advanced and supported in principle. Therefore, and based on a review of the online application register and consultee comments, it would appear likely that planning consent will be achieved within the next few months. The 128 dwellings proposed are also flatted, which further suggests that first completions will occur before 2026/27, which is the date identified in BBC’s trajectory.
6.34 Outline planning permission ref. 20/02155/MAO was granted on 26th August 2021, on The Beeches, High Street, Thurleigh, Bedford. The permission grants consent for 11 dwellings, with all matters reserved except for access. Whilst reserved matters still need to be submitted and conditions discharged, this appears to be a small-scale and straightforward site to deliver. This suggests that completions will take place before 2026/27, which is the timeline assumed in the BBC trajectory.
6.35 Noting the above, Boyer suggests the following indicative trajectory for these respective sites, in Table 2 below.
SEE ATTACHMENT FOR TABLE

Local Plan 2030 Allocations
6.36 In terms of the allocations proposed to be carried forward from the Local Plan 2030, the trajectory again appears to be excessively cautious. Wates understand that this is partly a reflection of the Plan-period for the adopted Local Plan 2030 (i.e., up to 2030) and the circumstances of the Examination into that Plan. Nonetheless, as BBC cites the trajectories for the allocations made within the 2030 Plan in support of the requirement for a stepped trajectory in the new Local Plan 2040, the assumptions for these sites must be revisited.
6.37 Policy 9 (P9) allocates Land at Duck Mill Land / Bedesman Lane for redevelopment, with BBC’s trajectory anticipating that 20 dwellings will be delivered at this site. Noting that the site is an underutilised ground level car park, within the urban area, there would appear to be potential for this land to deliver new homes prior to 2026/27, as is assumed in the BBC assessment.
6.38 Policy 11 (P11) identifies Land at Greyfriars for residential and town centre development and anticipates that around 250 dwellings will be achieved. Consistent with our previous comments, it is recognised that urban regeneration projects of the nature envisaged can take time to bring forward. However, to assume that no completions within this allocation (or the expansion envisaged in Local Plan 2030 Policy HOU1) before 2030/31, appears excessively cautious.
6.39 An outline planning application (ref. 20/00140/MAO) was submitted in January 2020 for 105 dwellings and other uses. Whilst application has yet to be determined, it does appear (from the application consultee responses) that consent will ultimately be achieved. Reserved Matters will need to be submitted following outline approval, before development can commence. However, even noting this requirement, it seems likely that first completions will be achieved prior to 2030/31.
6.40 Policy 12 (P12) allocates Ford End Road for development and the trajectory anticipates that 700 homes will be delivered at this site. Wates recognises that this site will take some time to deliver new homes, noting the need for coordination between multiple landonwners, masterplanning requirements and the obligation to achieve residential development without prejudice to the operational Eagle Brewery.
6.41 However, there are indications of progress. A Masterplan was approved and adopted in 2018. Planning approval has also been granted for remedial works (ref. 19/02446/MAF) on the gasworks site and the main condition of relevance (condition 4 ‘verification report’) was discharged in September 2020. It therefore seems plausible that redevelopment could now progress, allowing completions to occur prior to 2030/31, which is the date assumed in BBC’s trajectory.
6.42 Policy 13 allocates Land at Borough Hall and Prebend Street for development, with BBC’s trajectory identifying it as a source of supply for 225 homes, with first completions achieved in 2030/31. No planning application appears to have yet been progressed and Wates accept that this site wouldn’t meet the NPPF definition of ‘deliverable’ (i.e., completions within 5 years). Nonetheless, a masterplan was adopted by BBC in June 2018 and there do not appear to be any particular circumstances which suggest completions cannot be achieved prior to 2030/31, even if development comes forward on a phased basis.
6.43 Policy 14 allocates Land South of the River, Bedford, with the BBC trajectory anticipating that 1,000 dwellings will be provided from 2030/31. Wates recognises that this allocation incorporates several ownerships and is split across road and rail infrastructure. Nonetheless, the Local Plan 2030 Inspector’s Report at paragraphs 80 to 84 does acknowledge that some development may come forward prior to then, on a phased basis, which suggests that earlier delivery may be possible.
6.44 Policy 25 allocates Stewartby Brickworks, with the BBC trajectory in the Topic Paper suggesting that no completions well be achieved at this site prior to 2030/31. Wates does not dispute that the redevelopment of this large previously developed site presents challenges, and it is understood that the site’s owner is seeking a new development partner.
6.45 However, the site does benefit from outline approval (ref. 18/03022/EIA) for 1,000 homes and related infrastructure. Likewise, it is notable that BBC’s latest ‘Deliverable Sites Report’ (August 2021) identifies completions from 2024/25 onwards, with these completions appearing to be counted towards the claimed five-year housing land supply. Noting these factors, Wates considers that first completions could be achieved prior to 2030/31.
6.46 Policy 20 allocates Land at Mowbray Road and the trajectory assumes 124 dwellings will be delivered from 2026/27. Wates considers that this greenfield site, which does not appear to be reliant on significant new infrastructure, could come forward slightly sooner than anticipated by BBC.
6.47 Policy 21 allocates Land North of Beverley Crescent, with the BBC trajectory indicating that 150 dwellings will be delivered from 2026/27. Noting that this site is largely greenfield, adjoins an existing residential area, and does not appear to rely on significant new infrastructure for implementation. Wates therefore believes this site could come forward sooner than anticipated by BBC.
6.48 Policy 22 allocates Land at Lodge Hill, with BBC’s trajectory suggesting that 84 dwellings will come forward from 2026/27. Wates considers that this greenfield site, which does not appear to be reliant on significant new infrastructure, could come forward sooner than anticipated by BBC.
6.49 Policy 24 allocates Land at Grazehill, Bedford for residential development and the trajectory indicates that 163 dwellings will be delivered from 2022/23. Wates agrees with this estimate.
6.50 Taking account of the above, Table 3 (overleaf) presents Boyer’s updated assessment of the allocations in the Draft Local Plan 2030 (as a source of supply).
SEE ATTACHMENT FOR TABLE

6.51 On the basis of the above assessment of these three sources of supply (the proposed Local Plan 2040 allocations, existing commitments listed under ‘Approved Subject to S106’ in the Topic Paper and the Local Plan 2030 allocations), we consider that the following could be delivered, as set out in Table 4 below. The table amends the overall housing supply identified by BBC, so as to reflect the adjustments made in Tables 1, 2 and 3 above.
SEE ATTACHMENT FOR TABLE

6.52 It should be noted that the total claimed supply, in both BBC and Boyer’s analysis, exceeds the identified Standard Method LHN figure of 27,100 dwellings. Boyer’s total identified supply (28,481) is also slightly higher than that identified by BBC (28,352). This variation occurs because we have included the additional dwellings that Wates maintain can be provided at proposed allocation HOU15 (Land South of Wixams).
6.53 It should also be noted that we have proposed an alternative stepped requirement, which equates to the total LHN figure of 27,100. The supply would therefore exceed the requirement by approximately 4.9%, which is broadly consistent with the buffer identified BBC’s analysis.