Object

Representation ID: 10225

Received: 29/07/2022

Respondent: Mr Ben Pile

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 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).
[See attachment]
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.