Comment

Representation ID: 10120

Received: 29/07/2022

Respondent: Office of the Police and Crime Commissioner for Bedfordshire

Agent: Bidwells

General comments
Whilst agreeing that the allocation of site HOU8 is sound, I recognise that it is important that the development strategy as a whole is sound in order to ensure that development of my client’s site can be realised in the future. On this basis, I feel it prudent to note the below points in relation to the wider development strategy which I consider the Council need to be aware of moving forward:
• The average/peak delivery rates identified in the housing trajectory for large, strategic sites appear optimistic in a number of cases. Therefore, the level of housing that will be delivered in the plan period could be less than that expected by the Council. This reinforces the importance of allocating sites such as HOU8 but means that additional small-scale allocations may need to be proposed to underpin short term supply.
• Whilst the housing requirement is based on the Standard Method, I am uncertain if sufficient work has been undertaken to assess if a higher housing figure could be adopted. Again, this reinforces the need to maintain those site allocations proposed in the Plan but may necessitate additional allocations to make the Plan sound.
• It does not appear that there is a buffer in relation to land supply over and above the level needed to meet the current housing requirement. Again, this reinforces the need to maintain those sites currently proposed for allocation in the Plan but may also necessitate the allocation of other sites to
support overall delivery rates and make the Plan sound.