Object

Representation ID: 10125

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

c) Relationship With The Proposed Requirement for a Stepped Trajectory
3.12 PPG ID: 68-021-20190722 notes that a stepped trajectory may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies or to accommodate the phasing of strategic sites. The PPG also addresses how past shortfalls should be considered when assessing housing completions against planned requirements (PPG 68-031).
3.13 For Bedford it is correct that upon commencement of the new plan period from 2020 past under-delivery or over-delivery prior to this date is reflected in the result of the calculation of the standard method and application of the affordability adjustment (ID: 68-031-20190722). This is a significant point. The Council previously argued that it was necessary to calculate any surplus/’oversupply’ against the NPPF (2012)-derived objectively assessed need of 970dpa prior to 2020, That argument has now been completely negated.
3.14 It is also relevant to note the contents of the PPG in respect of local housing need. PPG ID: 2a-010-20201216 notes that previous levels of housing delivery may be a relevant indicator in considering whether to plan for needs greater than those indicated by the result of the standard method.
3.15 The following points further demonstrate, with reference to the Local Plan 2030 and PPG ID: 68-021-20190722, that reliance on the stepped trajectory proposed by the Council is not justified in the circumstances.
3.16 Firstly, recent levels of delivery broadly accord with the outputs of the standard method, notwithstanding a small reduction in output between 2019/20 and 2020/21. This is not surprising, with the upturn in completions since 2015 largely being reflective of rectifying (in- part) early delays to achieving the growth ambitions of the area reflected in the 2008 Core Strategy/Regional Spatial Strategy and delivery of commitments first identified in earlier plans.
3.17 It is worth reiterating that in terms of recent levels of delivery and their relationship with housing need the need to address these earlier delays is reflected in the standard methodology and its measures to address worsening affordability as well as enabling sustainable commuting patterns. The earlier conclusions of the Council’s consultants, Opinion Research Services (ORS) that the 2014-based projections from which the standard method is derived are likely to overestimate future growth (due to perceived errors in the 2011 Census estimates) have been proven incorrect by the most recent 2021 Census estimates.
3.18 Projected growth in the 2014-based series has been met and exceeded to 2021, as shown in the comparison below in Figure 1 below, albeit annual rates of delivery below have been slightly below the current calculation of LHN.
[See Fig 1 in attachment]
3.19 While this does not itself indicate a need to plan for a higher level of need than indicated by the result of the standard method the trend is indicative of high levels of market demand and suggests that minimum local housing need provides a stable basis for plan-making in the area, as intended by Government. The requirement under national policy to sustain these trends is neither new, surprising or unexpected.
3.20 The difference between the 2021 Census estimate and the 2018-based subnational population projections used in the Council’s demographic analysis of utilising a stepped trajectory9 is around +9,000 persons. This is at least in-part likely to be a result of substantially higher net in-migration to the area than recorded in previous official mid-year estimates (as set out in Figure 8 of the Council’s analysis). The impact on levels of population and household growth relative to recent trends will therefore be substantially greater than indicated in the Council’s current evidence base.
3.21 Making provision for a downward step-change as indicated by the Council’s trajectory is the antithesis of securing the Government’s objective to boost supply under NPPF 60. Compared to recent trends it is likely to encourage adverse effects in terms of affordability, household formation, commuting patterns and supporting growth of the labour force locally consistent with the Council’s ambitions for economic development. Implementing a stepped trajectory as proposed by the Council is therefore inconsistent with numerous facets of national policy and guidance and its introduction must be very carefully considered in order to cause the minimum possible delay to meeting future needs.
3.22 Secondly, recent levels of completions have been achieved within the context of overall policies of significant restraint in the rural area, prior to the conclusions of the Local Plan 2030 that in principle the spatial strategy could sustainably cater for the distribution of growth to Key Service Centres and Rural Service Centres.
3.23 Thirdly, in relation to the phasing of strategic sites the PPG must be considered in the context of earlier plan-making. The Council has had many years, including the entire Local Plan 2030 process, to have identified and made strategic land allocations at earlier stages. In seeking an earlier ‘reprieve’ while still suggesting its current Local Plan met national policy objectives to boost supply the Council could be expected to accommodate a spatial strategy that would have minimal implications for supporting the long-term phasing of new strategic sites in the future. The stepped trajectory now proposed demonstrates that this is not the case. Total delivery proposed in the Council's stepped trajectory for the period 2020 to 2030 (10,100 dwellings – assuming the Council’s delivery forecasts for identified sites are robust) is only around 800 dwellings greater than the LP2030 trajectory for the same period (9,281 dwellings). This indicates little if any effective plan-led response to boosting supply to meet needs within the Plan for Submission. In now reiterating concerns regarding the phasing of strategic sites, having opted not to allocate these at earlier stages, the Council is further compounding the challenge of delivery and relying on past excuses to defer meeting needs.
3.24 Fourth – and most significantly – the Council’s conclusion is fundamentally reliant on acknowledging that the LP2030 strategy was and has been incapable of meeting expectations for a boost in supply 2020-2025. For the same five-year period the LP2030 housing trajectory anticipated delivery of around 1,120 dwellings per annum. This cannot be regarded as a significant change from the requirement to satisfy local housing need, which the Council was already aware of. In reality the Council now acknowledges that the whole strategy upon which it relied to adopt the LP2030 has in effect been deferred backwards into the plan period, hence a proposed stepped trajectory for this period of 970dpa (over 13% below the expectations from its own Plan adopted less than three years ago).
3.25 Acknowledging these past failures should provide clear justification to prioritise sites that can be delivered early in the plan period, in accordance with the PPG (ID: 68-021-20190722) rather than reinforcing reasons to delay meeting needs. This is considered further below. The Council’s proposed use of a step trajectory, particularly to the extent proposed, simply extends to gap between a failed strategy and identifying opportunities to meet needs in full (or even to ensure that the prospects for delivery secure levels of completions recorded pre- 2021)
d) Failures in Delivery of Provision Identified Within the Local Plan 2030
3.26 The delays and failures in respect of the Bedford Local Plan 2030 are most evident when considering the trajectories of the 2030 Plan and 2040 Plan for individual sites and locations for growth. It is here that we can see an acute problem with the delivery of allocated sites. In a number of instances, some of which are highlighted below, delivery on allocated sites, including a large capacity for housing identified in Bedford Town Centre, has simply been pushed back from that expected on adoption of the 2030 Plan.
3.27 For instance, the Greyfrairs allocation was expected to deliver circa 70 dwellings per annum from 2021 in the 2030 trajectory (200 in total), whilst the 2040 trajectory pushes back first delivery to 2029 and reduces build out to 50 dwellings per annum.
3.28 The same is true of the large Ford End allocation, were delivery was expected to commence in 2021 at a rate of between 68 and 117 dwellings per annum (630 in total). Again the 2040 trajectory pushes delivery back to 2029 and expects a rate of between 50 and 75 dwellings per annum (700 in total).The below table sets out some key differences;
[See Table 4 in attachment.]
The same is true of the Neighbourhood Development Plan allocations as demonstrated below (note these assumptions are without prejudice to our client’s position regarding the assessment of deliverability in each case);
[See Table 5 in attachment.]
e) Reliance Upon Supply from Unidentified Sites within the Local Plan 2040
3.29 It is further noted that there has been a jump in the number of windfall sites anticipated throughout the Plan period against the 2030 Plan period. The LP2030 housing trajectory includes a total of 958 dwellings for the period 2020-2030, whereas the Council’s Stepped Trajectory includes 148dpa from 2021/22 to 2025/26 and 135dpa thereafter (equivalent total to 2030 of 1,280). These totals include the Council’s allowance for delivery on small sites (0- 4 dwellings) not captured separately in the trajectory but are also inclusive of a figure of 90dpa windfall on sites comprising 5-24 units in the urban area as set out in Appendix 2 of the Council’s most recent Housing Land Supply Assessment.
3.30 Average windfall supply from the 5-24 units component has increased since 2016/17, which is very likely to be a function of trends related to conversion under Permitted Development Rights but not subject to any detailed assessment of whether these trends can realistically be expected to continue as part of the Council’s evidence base (and as required by NPPF2021 Para 71). This will need to be fully justified and upon further evidence, and we retain the right to explore the windfall allowance further. This is particularly important where the Plan for Submission also seeks to specifically allocate several sites of under 25 dwellings and therefore the Council must ensure no ‘double-counting’ of these sources of supply. The policy proposals within the Plan for Submission, such as Policy DM5 relating to thresholds for the provision of self-build plots from small sites, may also impact upon windfall supply.
3.31 In any event, the difference in the approach to total identified provision between the LP2030 and LP2040 trajectories is not reflective of a plan-led response to boosting supply and does not offer any support for the reasons to rely on a stepped trajectory. If past rates of windfall supply are not maintained there will be a further increase in the ‘gap’ to meeting needs in full.
f) Summary and Updated Delivery Assessment
3.32 It is clear that even after just 2 years from adoption, there are considerable issues with the strategy and allocations contained within the 2030 Plan. Notwithstanding, our continued assertion that the adopted housing requirement of 970 dwelling per annum was artificially constrained and not reflect of the full objectively assessed need for housing, we have considered the Council’s claimed housing land supply again this requirement for the next 5 plan years.
3.33 The sites assessed here and considered in the Council’s latest trajectory almost exclusively comprise existing allocation from the 2030 Plan, some of which were carried forward from the 2002 Plan.
3.34 As demonstrated within the supporting Deliverability Assessment Update (copy at Appendix 1), we have concerns that the Council will not be able to demonstrate a supply at adoption and furthermore, will be unable to demonstrate a supply at the 2nd and 3rd step of the trajectory.
3.35 Having reviewed the sites in detail we have identified common issues that are contributing to this expected shortfall over the next few years.
3.36 In particular we have identified that the Local Plan 2030 carried forward a number of Town Centre sites from the 2002 Plan and the sites have thus far failed to deliver the level of growth anticipated. It is understood that viability is a key component of the issue here, with previous viability work supporting the 2030 Plan having significantly over-estimated land values, which subsequently cannot be achieved. In allocating so many sites in the Town Centre the Local Plan 2030 also exposes known issues surrounding delivery rates, achieving an appropriate housing mix (including provision of family housing), securing affordable housing and securing provision for the housing needs of different groups
3.37 There has been a notable failure to address local priorities for matters including community, social, and green infrastructure as well as enhancing existing facilities and job opportunities/ This is because the allocation of land in Key Service Centres and Rural Service Centres was in the 2030 Plan largely deferred to Neighbourhood Development Plans.
3.38 Whilst we supported a strategy that included development in these areas, almost all of the Neighbourhood Development Plans have opted to accommodate their apportioned growth in one large allocation. Concerns relating essentially to the allocation of strategic scale growth through NDPs have been well-document as part of previous representations on behalf of our clients relating to the relevant Local Plan 2030 and NDP processes. The resultant delays to delivery and shortcomings in the ability of the NDP process to identify and secure improvements to local infrastructure, services and facilities are not unexpected. This is an inevitability where these strategic priorities have been deferred from the Local Plan-making exercise and realistically required more detailed testing than that carried out throughout the Neighbourhood Development Plan process.
3.39 The absence of sufficient flexibility in the allocation of land in the 2030 Plan further compounds this issue and ultimately results in the Council not being able to respond to circumstances, such as those set out above, whereby delivery is delayed or coming forward at a slower pace than anticipated. The Council should seek to ensure that this mistake is not made again, particularly when considering the overriding reliance on strategic scale growth proposed in the 2040 Plan.
3.40 In summary the Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the Government’s latest policy with full awareness of these issues. Pursuing a stepped trajectory, particularly in the context of the housing requirements identified by the Council, simply perpetuates these problems.