Object

Representation ID: 8506

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
This sits alongside strategic decisions where direction will be provided by the Framework e.g., implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
The Council’s proposed in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.