Object

Representation ID: 10207

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and Timing of Housing Growth (DS3(S))
2.16 The plan covers a 20-year period from 2020-2040 and the spatial strategy deployed in this case sees development and delivery of much needed residential units delayed until the latter half of the plan period to facilitate the lengthy preparation, consultation, submission and consideration of planning applications and the delivery of infrastructure to support existing and future residents. Draft Policy DS3(3) sets out the delivery of housing throughout this period, identifying 9,700 units to be delivered in the first 10-year period and 17,000 to be delivered in the second 10-year period. This is a wholly unrealistic breakdown and places extreme pressure on the second half of the plan. On an annual basis the final ten years of the plan expects a rate of delivery that is nearly twice the previous ten years. Moreover, this has never been achieved in Bedford borough, historically.
2.17 As context, the Housing delivery test identified that in the past three years, Bedford has delivered 964, 1255, 1371, 1371, 1026, and 1203 dwellings per annum in the past 6 years respectively. Significantly below the expectation of 1,700 per annum per year over 10 years. There is a very strong likelihood that the delivery in the second half of the period will delay and reduce leaving a potential huge undersupply of homes.
2.18 Whilst the Council can demonstrate a 5-year housing land supply at this time, this stepped approach that sees housing unevenly distributed throughout the plan period may quickly lead to an under supply. The need for this plan to identify and allocate additional small and medium sites to deliver early homes within the plan period is essential to prevent later delays.
2.19 The STPP trajectory provides an overoptimistic estimation for the delivery of HOU14, HOU16 and Little Barford in particular. To consider that these are reliant on rail and road infrastructure delivery including East West Rail and the infamous A1 ‘Black cat’ roundabout works suggest that first completions are expected in 2030 is simply not realistic. That in year 1, each of those sites are proposed to deliver a minimum of 100 units in the first year is also unrealistic, even if they start on 1st April 2030. To suggest that they might achieve completions of 200 plus from year 2 reaching a staggering 600 units per annum in 2037 at Little Barford is without credibility. Wixams has only delivered around 180 per annum on average over its entire period of delivery.
2.20 It is worth noting that there are three major sites that are relying on the infrastructure being in place for completions to start on site in 2030, therefore it only takes one of those sites to fall-behind and the trajectory is quickly undermined. Although spreading the risk might be considered a benefit on one hand it also increases the risk of partial failure as there are three chances of that happening.
Reliance on outside bodies to deliver vital infrastructure
2.21 The Stepped Trajectory Topic Paper (April 2022) that supports this plan has sought to justify the approach applied to housing delivery in the draft Local Plan. This document notes that “development at the scale required by the Standard Method requires investment at a commensurate scale to unlock growth”. Whilst it is acknowledged that the Standard Method identifies high demand for housing and a comprehensive approach in response to this is required, it is considered that the provision of strategic greenfield development and two new settlements exacerbates this need for investment. Furthermore, if the logic is that large new settlements is an essential long-term solution to the high requirement, then pragmatically the delivery of those settlements should be phased over multiple Local Plans and not compressed into one. History shows that new settlements take more than 20 years to evolve and then complete and this significantly longer than the present plan timetable.
2.22 The STTP at para 2.2 identifies “in particular” both East West Rail and strategic highway improvements need to be delivered to successfully meet the trajectory proposed. These two constraints are extremely difficult to predict and rely on delivery outside of the control of Bedford Borough Council and the land promoters of the sites that rely on their delivery. To base 88% of all allocations in this plan on the delivery of further rail, road and other strategic investment, there needs to be an acknowledgement of the past and a trajectory that builds in flexibility and has a cautious approach to delivery.
Recognising comparable cases (Wixams)
2.23 One of the many rail infrastructure requirements is the new station at Wixams, apparently proposed to be operational by 2024. Assuming this is a correct estimation, and this will no doubt be tested at EiP, one only has to look at how the estimation for this being delivered have over time been delayed; from being an essential requirement and justification for the original designation of the Wixams new settlement, the station has become an afterthought, and will be delivered significantly later than expected. (see Wixams a pertinent case study overleaf – Figure 2).
2.24 This is the credibility of evidence that the Council needs to reflect upon as they build their trajectory and their basis for identifying strategic sites. Knowledge of the past flawed predictions should be taken as a warning to avoid future failure. Wixams is a case that demonstrates the difficulty of making predications on the delivery of key infrastructure that rely on outside control.
The STPP trajectory is flawed
2.25 In short, the trajectory lacks realism, both in terms of the start date for completions and the annual delivery and is therefore highly risky. Reliance on infrastructure provision that is itself reliant on outside bodies undermines the soundness of the trajectory. The STPP lacks realism and there is no recognition to the experiences of the past, such as Wixams, and failing to have regard to such an important understanding of the issues that are faced undermines the credibility and soundness of this plan.
A phased approach to delivery
3.9 As stated above, the council has sought to protect the settlements in the rural area where an existing NP exists. These NPs cover the period to 2030, therefore there is an opportunity to identify land in these communities post 2030. This can either be through a NP review or and for greater certainty we advocate that specific allocations are made in this plan as Post-2030 allocations. This is a phased approach that it is not uncommon, for example Rochford District Council in Essex applied a two phased approach with a policy that allowed the post-2021 sites. For flexibility these could also be brought forward early under certain triggers such as a lack of a five-year land supply.
3.10 The reason why this would work in Bedford Borough is that it would protect the delivery of the NPs and give time for the forward infrastructure delivery of other key strategic sites to make progress and come forward. These Post-2030 sites can then be identified for inclusion in any future LP or NP or be part of a process of delivering dwellings post-2030 alongside other strategic sites.
3.11 It should be noted also that the requirement for 2020-2040 is to deliver an annual 1355 dwellings per annum over the 20 year period (based on 27,100 homes in the period 2020-2040). This requirement begins at 2020 and is higher than the requirement set out in the adopted plan for the same year which is 970 per annum (based on 14,550 homes in the period 2015-30). This demonstrates that in the early years of this plan there is a significant uplift required (385 per annum) before the strategic sites contribute and the best location for this is in the Rural Areas. This should be read alongside the evidence that in 2020 the Housing Delivery Test demonstrated that the deliver was between 1026 and 1203 dwellings in 2020 and therefore the plan in 2020 is already underdelivering against a requirement of 1355 per annum.
3.12 The period 2030-2040 in this plan already looks like a daunting challenge and that period does not have any small to medium sites proposed and an opportunity is being missed to deliver sites that are capable of early releases of housing. This approach will allow a greater number and diversity of sites releasing housing across all of the Borough with all capable of contributing to land supply without the issues of an over concentration in one place.
3.13 If this site is not considered an acceptable site for the first ten years of this plan, as we believe it should be we would ask that it is considered as an inclusion in a phased strategy post 2030.