Object

Representation ID: 10158

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable site’s leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of site’s. All the brownfield site’s will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack site’s from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated site’s.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting site’s that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large site’s that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.