Object

Representation ID: 10500

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management supports the approach to the level of housing growth required, which as a “starting point” is set at 1,355 dwellings per annum and represents a significant uplift from the Local Plan 2030 requirement of 970 dwellings per annum. The level of growth also represents a further increase from the 1,275 dwellings per annum identified in the Draft Plan Strategy Options and Draft Plan consultation (see para 3.2).

In context, however, of the scale of uplift required and significant challenges in terms of housing delivery, Hallam objects to the proposed stepped trajectory, which is considered to be inappropriate for achieving an even and consistent level of housing delivery to meet the Borough’s housing needs. In this context Hallam considers that the plan does not meet the tests of soundness.
The amount and timing of housing growth example suggested in the Policy seeks to provide for 27,100 new dwellings with the delivery of 970 dwellings per annum until 2024/25 then stepped to 1,050 dwellings in the period 2025/26 – 2029/30 and then 1,700 dwellings per annum from 2030/31 until 2039/40. The stepped trajectory equates to a significant uplift in housing delivery, first by a modest 8.2% after 2024/25 and then by a substantial 61.9%after 2030/31. It builds in the postponement of measures to meet immediate need, and it increases substantially the level of risk built into the plan since the effects of any under-delivery of stepped housing requirements on housing need would be greatly exacerbated. There would be little opportunity to redress any under-delivery in the highly stepped targets at the end of the plan period.
Evidence, in Bedford Borough Council’s interim Housing Monitoring Report 2020-21 demonstrates that rates of housing delivery from 2015/16 to 2020/21 have ranged between 964 dwellings per annum and 1,359 dwellings per annum but overall, have supported the delivery of housing at an average rate of 1,192 dwellings per annum – well above the 970 dwellings per annum planned for up to 2024/25 and the 1,050 per annum planned for up to 2030.
Hallam considers that planning for a rate of delivery constrained to 970 dwellings in 2020/21-2025/26 and with just a modest increase to 1,050 to 2029/30 would be a constraint to growth, well below current delivery rates. With a lack of planned deliverable sites that could be brought forward sooner, a reduced rate will create a significant cumulative underbuild towards 2030/31. Such an approach, in turn, is likely to undermine wider growth and planning objectives. Failing to plan adequately for a sufficient supply of sites to come forward in the short and medium term, in the face of current higher delivery rates, and with sites in sustainable locations that are available to come forward if they are allocated, runs counter to paragraph 68 of the NPPF. Planning for lower rates will frustrate and provide no incentive to deliver sustainable development and growth opportunities in the early years of the Plan.