Comment

Representation ID: 10070

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

Emerging policy DS5 sets out where growth is to be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040.
2.35 Emerging policy DS5(S) sets out the following distribution of housing growth:
Location - within the urban area, dwellings - 1200, Employment land (ha) - 5
Location - Strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale
incorporating the Bedford Milton Keynes Waterway Park and the Bedford River Valley Park, dwellings - 1500, Employment land (ha) - 7

Location -Growth locations on the A421 transport corridor and with the potential for rail based growth
- South of Bedford including new settlement (land parcels at Wixams, Shortstown and Elstow) - dwellings - 7,050, employment land (ha) 70
- Little Barford new settlement, dwellings 3,800, employmnet (ha) 4
- Other employment sites (50ha)

Location - Some development will take place beyond the plan period - dwellings - 400

location - Remaining rural area / villages (including Tuvey)
dwellings - Completion of sites previously allocated in local plans and neighbourhood plans

As detailed in response to Policy DS2 it is considered that the Council’s preferred strategy is over reliant on strategic sites and new settlements and is not sound. The approach proposed risks the delivery of the Plan as it is highly vulnerable to delayed or non-delivery. If one of the strategic sites does not deliver than the Plan will fail. Further, the approach adopted by the Council does not provide for choice and competition in the housing land market, which is likely to result in land price inflation given most the new housing is under the control of a limited number of landowners. Moreover, it largely rules out developments being brought forward by SME housebuilders, instead creating a monopoly of sites which can likely only be delivered by the larger housebuilders who will benefit from the economies of scale. As a result, there will also be a limited variety of houses realising to the market concurrently, slowing market absorption which will have high consequences in the latter years of the Plan period in terms of satisfying the Housing Delivery Test or demonstrating a five-year housing land supply.
2.37 The Plan states that there will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres however, no new/additional allocations are made in these villages in the Local Plan 2040.
2.38 The Plan instead advises that some Parish Councils may choose to allocate further sites for development in their Neighbourhood Plan; there is no requirement for this.

absence of small and medium growth in the rural villages misses an opportunity to deliver some of the housing requirement earlier on in the Plan period, rather than relying on some 10,000 dwellings to be delivered through new settlements which are significantly reliant on the delivery of large-scale infrastructure. As detailed in response to PolicyDS3 it is not an appropriate strategy to place such a reliance on strategic infrastructure to deliver such a large proportion of a housing need, particularly when the Council’s own evidence (Bedford Local Plan 2040 – Borough Wide Viability Study, April 2022) confirms that strategic sites will not be able to deliver the policy requirements, including affordable housing. Allocating small to medium sites, will ensure that the Borough’s housing needs are delivered, quickly, at policy compliant levels, delivering homes for all need which will not be achieved through the new settlements.
2.40 The evidence base which supported the previous Local Plan 2030 and initial drafts of that Local Plan confirmed that there is capacity within the smaller settlements to deliver a higher quantum of growth than was adopted through the Plan (up to 150 dwellings in each settlement rather than the 25 – 50 dwellings detailed within the Plan). The Plan states that it is not possible to provide additional housing in the early years of the Plan period, but this is not justified. Its own evidence has clearly demonstrated that settlements such as Turvey are suitable for a higher quantum of growth than currently being delivered under the adopted Plan.
2.41 The distribution of growth within the LP2040 is not effective. As detailed in response to Policy DS3, such a reliance on strategic sites is not deliverable over the Plan period (it is already noted in policy DS5(S) that 400 dwellings will be delivered beyond the plan period, before accounting for any delays in site assembly, unlocking and delivering the required infrastructure, and actually delivering homes on sites included within the plan period).