Object

Representation ID: 10501

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam objects to the proposed distribution of growth, which is linked to concerns with the proposed spatial strategy in Policy DS2(S) and amount and timing of growth to be delivered expressed in Policy DS3(S). In this context the policy undermines the soundness of the plan.
Hallam considers that the proposed distribution is heavily skewed towards the Growth Locations on the A421 Corridor and with the potential for rail based growth. The overreliance is reflected in, and predicated upon, the stepped housing trajectory, which as a result of longer lead in times to allow for adequate infrastructure investment will result in rates of delivery well below the annual housing requirement of 1,335 dwellings until 2030/31. The primary objection is that this distribution of growth suggests a restriction in the supply of smaller sites, relying on those currently allocated to deliver housing below the average rates of delivery achieved over the last six years, which is evidenced to be at an average rate of 1,192 dwellings per annum (Bedford Borough Council Interim Housing Monitoring Report 2020-2021). Moreover it may be served to preclude the delivery of other highly sustainable options for contributing to the growth objectives of the Plan. In representations on Policy DS2(S)the clear case for the inclusion of Clapham within the Spatial and Distribution Strategy is made. Specifically, in particular the opportunity should be taken to accommodate additional numbers at the settlement or to redirect allocations from the south of the town where the overconcentration of allocations leads to the greatest impacts in terms of transport and infrastructure.
The NPPF, in paragraph 60, requires a sufficient amount and variety of land to come forward where it is needed. The NPPF later states in paragraph 68 that planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and viability. Consistent with Hallam’s rationale that underpins the requested modifications to the Policy DS2(S) Spatial strategy and Policy DS3(S).