Object

Representation ID: 7370

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

Lone Star have concerns regarding the potential reliance within the draft Local Plan of use of a stepped trajectory, as set out at para 3.5. The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the emerging strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.
If the Council decide that the provision of large strategic sites is an important part of site delivery in the Borough, then the changes in the National Planning Policy Framework (“NPPF”) published in July 2021, now provide a sound policy context for Local Plans to include such proposals within the context of a 30-year Vision to recognise their longer lead in times, and prolonged delivery (NPPF para 22). The delivery of larger sites, therefore, is not a sound reason for failing to meet the aspirations of those in housing need now.
The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6 – 10. The NPPF does not support the deferral of meeting the known housing requirement to beyond year 10. The PPG (68-021) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.
The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.
is simply being deferred to later in the Plan period without justification.
Lone Star Land would encourage a strategy which does not seek to delay meeting housing need through a stepped trajectory. In order to achieve the Standard Methodology (“SM”) figure, as a minimum, the strategy should allow for a greater number of small and medium sized sites to be delivered, which are capable of being brought forward within the first 10 years of the Plan period, to meet the current need, now.
Such a strategy should necessarily look to reliance on the delivery of sites at those settlements that are consistent with the locational strategy of the emerging plan (i.e. those sites which lie, inter alia, on the A421 corridor) and settlements which have been assessed and been found by the Council to be highly sustainable in their own right, i.e. the Key Service Centres, including Great Barford.
That Great Barford only appears in one of the four Option 2 scenarios, is without any sense of evidential support or justification. As aforementioned, the Settlement Hierarchy background paper concludes that it is a highly sustainable settlement with a full range of local services to meet day to day community needs, it is close to and well connected to Bedford, with frequent public transport service provision, and is able to support further growth demonstrably without causing environmental, landscape or heritage harm, through the delivery of sites such as that promoted by Lone Star Land.
August 2021 | KF | P19-0021 Page | 8
The Council are therefore invited to review the trajectory of delivery for their Reg 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.
With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy may reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.