Object

Representation ID: 10127

Received: 29/07/2022

Respondent: Bletsoes

Agent: Rosconn Strategic Land

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RSL are of the opinion Policy DS3(S) is unsound as it is not consistent with the requirements of national policy.
During the examination of the Local Plan 2030, the Inspector required the Council to undertake and submit a review of the Plan for examination within three years of its adoption on the basis that the current housing requirement of 970 dwellings per annum was based on the previous housing needs methodology, and not the Standard Methodology. Therefore, the Council needs to consider the review in the context of the elevated housing requirement as set out in the Standard Methodology. This version of the Draft Plan has retained the use of a stepped trajectory to deliver homes within the plan period up to 2040, whereby it is expected that 970 dwellings per annum (dpa) will be delivered in the period up to 2024/25, rising to 1050dpa up to 2029/30 and then to 1,700dpa up to 2039/40. The Council’s justification for the use of the stepped trajectory is in order to adapt to the significant increase in the annual housing requirement (from 970 dpa in the Local Plan 2030 to 1,355dpa which is an uplift of 40%) and the need to link growth to the completion of new infrastructure.
Paragraph 68-021-20190722 of the PPG states that using a stepped requirement must be evidenced by the policy maker and must not seek to unnecessarily delay meeting identified development needs. RSL are of the opinion the approach of pushing the majority of homes to be delivered towards the last 10 years of the plan period rather than seeking to address the uplift in housing need at the earliest opportunity in the plan period will undoubtedly create a far greater burden between 2030 and 2040 on the Borough. RSL note that the annual delivery of new homes as suggested in the proposed stepped trajectory will not exceed, or even equate to, the identified minimum annual requirement calculated by the Standard Method for the Borough until beyond 2030. The Council, therefore, are at risk of unnecessarily delaying meeting the identified development needs for the Borough, contrary to NPPF para 60.
As a consequence of this, the Council are not addressing the housing affordability issue in the Borough which exist now. According to the most recent affordability ratios published in March 2022, Bedford’s affordability ratio increased by 1.27, indicating affordability has significantly worsened in the year between 2020 (8.92) and 2021 (10.19). This is higher than England’s average ratio estimate that full-time employees could typically expect to spend their annual earnings on purchasing a home (9.1). RSL consider that the proposed stepped trajectory as currently outlined significantly risks affordability in the Borough worsening unnecessarily up to 2040. As such, in RSL’s opinion, the Council need to reconsider the stepped trajectory accordingly to not delay addressing the affordability issue.
Having adopted a spatial strategy that is not consistent with national policy (as set out in RSL’s response to Policy DS2(S)) it has resulted in the need for the Council to use a stepped trajectory which has the effect of delaying the delivery of housing for the first 17 years of the plan period. In the context of a housing crisis and housing affordability worsening, RSL consider the Plan fails to positively prepare for the area’s objectively assessed needs, provide sufficient justification that the strategy is appropriate, deliverable over the plan period and consistent with national policy as set out in paragraph 35 of the NPPF. As such, RSL consider the Plan unsound.