Object

Representation ID: 6356

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

The standard method figure for Bedford Borough is set out in Chapter 3 of the consultation document at 1,275 dwellings per year (25,500 dwellings in total). With existing commitments taken into account, the plan will therefore need to allocate land to provide a minimum on 12,500 new dwellings.
However, it has not been made clear in what has been published whether the existing commitments that have been identified include the emerging Neighbourhood Plan allocations
(which are intended to satisfy the requirements of adopted Local Plan policy 4S). Should these be taken into account as commitments, the minimum level of growth that will need to be delivered in the Local Plan may need to increase should any of the emerging Neighbourhood Plans fail to come forward, fail at examination or not pass referendum.
It should also be stressed that the 25,500 housing requirement identified as part of the standard methodology is the minimum number of homes that need to be delivered over the plan period for the Bedford Local Plan 2040. There will need to be an additional allowance made in the allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays in order to ensure that this figure is delivered.
It is common practice to make an additional allowance of 10%, equating to land for 2,550 homes over the minimum, in order to ensure that there is an appropriate contingency in place for under delivery. At paragraph 1.50 of the published Draft Strategy Options Document there is reference to ‘choice and flexibility’, however this comment is only made in relation to the potential additional growth that could come forward via neighbourhood plans. As a result of this proposed approach, the amount of new homes delivered through neighbourhood plans is an unknown and therefore it is important to ensure the delivery of the minimum number of homes planned for in the Local Plan is in excess of the required 25,500 to allow for this.
Taylor Wimpey therefore consider that 28,050 homes (25,500 +10%) should be planned for rather than the 25,500 currently considered in each of the options that have been identified. This approach would also help to ensure that the requirements of paragraph 68 of the NPPF, which stipulates that council’s should plan for a deliverable supply of land for years 1-5 of the plan plus an appropriate buffer to be identified, will be met.

Housing Requirement
Additional land should be identified to provide a buffer beyond the base number identified in the standard methodology in order to create flexibility and contingency in the supply.

Where Neighborhood Plans have not come forward or have failed at examination, and therefore no development sites have been allocated as is required under the adopted Local Plan, the Local plan should allocate sites to meet this need.