Object

Representation ID: 8403

Received: 27/09/2021

Respondent: WSP

Agent: WSP

The Draft Plan outlines four options for the future ‘Growth and Spatial Strategy’ and asks:
“What, in the context of the vision and objectives outlined earlier in the document, is the appropriate spatial strategy for the plan?”
Option 2d (development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes and east parishes, plus one new settlement) represents the optimal and most sustainable option for the borough’s growth and spatial strategy.
The Draft Plan outlines that Option 2d will provide between 12,500 and 13,085 dwellings. This is the one only option that provides over the requirement of the standard method and meets the uplift in housing need outlined in the Council’s LHNA. This therefore the option that complies with the requirement of Paragraphs 60 and 61 of the NPPF.
Paragraph 60 of the NPPF outlines the Government’s objective of significantly boosting the supply of homes. This suggests that Council’s should provide above the minimum housing need identified using the standard method and local housing need assessments (per Paragraph 61 of the NPPF), a view that was taken by an Inspector in a recent appeal1 concerning BBC (in April 2021). This reading of the NPPF suggests that it is clear that the upper limits of housing need should be supported and therefore provides justification for the adoption of Option 2d.
The Government’s objective for significantly boosting the supply of homes (Paragraph 60 of the NPPF) notes that in order to ensure that this can be supported, a sufficient amount and variety of land should come forward where it is needed. This is emphasised by Paragraph 69 which outlines the contribution that small and medium sized sites can make to meeting the housing requirement of the area, noting that 10% of housing delivery can be undertaken on these sites.
Paragraph 69 therefore supports the progression of Option 2d to be selected as the preferred option for the growth and special strategy of the draft Local Plan. This is as Option 2d while it
1 APP/K0235/W/20/3263447

provides much needed dwellings in large scale urban extensions and new settlements (which is supported by Paragraph 73 of the NPPF), it accounts for the parishes of Bedford, which are likely to be able to support smaller and medium sized sites with greater ease. Option 2d is therefore supported by both Paragraphs 69 and 73 of the NPPF as it would enable both small and large sites to come forward for development and significantly boost housing delivery.