Object

Representation ID: 9008

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section of the representations should be read alongside the separate Delivery
Assessment included at Appendix 5. This addresses the ability of the Council approach to
maintain a rolling five year supply of deliverable sites (including as part of its proposed use
of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery
Assessment also illustrates that the Council is unable to demonstrate a five year supply of
deliverable sites based on its own published position (at a base date of 1 April 2019) or when
this is rolled forward to 1 April 2021.

In summary, the Council’s proposed approach to managing the delivery of housing over the
Plan period is unsound. The Council indicates a proposed 20-year Plan period (2020 to 2040)
for the Local Plan Review. The Local Plan Review must meet minimum annual local housing
need calculated in accordance with the standard method. Planning Practice Guidance ID:
68-031-20190722 answers the question ‘how can past shortfalls in housing completions
against planned requirements be addressed’? and states:
“Where the Standard Method for assessing local housing need is used as the starting point
in forming the planned requirement for housing, Step 2 of the Standard Method factors in
past under-delivery as part of the affordability ratio, so there is no requirement to
specifically address under-delivery separately when establishing the minimum annual local
housing need figure. Under-delivery may need to be considered where the Plan being
prepared is part way through its proposed Plan period, and delivery falls below the housing
requirement level set out in the emerging relevant strategic policies for housing.”

Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will
be relevant to assessing the soundness of the Local Plan 2040. Performance for this period
will therefore be substantially informed by the Council’s current evidence of deliverable
supply against the Local Plan 2030 housing trajectory (and extant consents).

The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on
a ‘stepped trajectory’ for the Plan period to 2030 (retaining an annual requirement of 970
dwellings per annum). The Preferred Options principally rely on large-scale strategic sites
with limited prospects for delivery within five years from adoption (2023 to 2028). The
Council’s supply for this period will therefore also substantially be informed by the Local Plan
2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).

The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed
in the separate Delivery Assessment, demonstrates that these do not achieve an early
prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030
Examination relating to constraints to viability and availability of the sites identified,
particularly within the Town Centre.

Regarding Town Centre sites identified in the Local Plan 2030 and the associated
longstanding delays to development there is no mention of a Development Corporation in
either the Council’s consultation document or consultation on a Vision for the Oxford-
Cambridge Spatial Framework. The Council has previously indicated that this may be the
route to unlocking sites and overcoming barriers to development for which there is currently
no clear solution.

In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary
to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a
stepped requirement appropriate for plan-making’? and sets out:
“A stepped housing requirement may be appropriate where there is to be a significant
change in the level of housing requirement between emerging and previous policies
and / or where strategic sites will have a phased delivery or are likely to be delivered later
in the plan period. Strategic policy-makers will need to identify the stepped requirement in
strategic housing policy, and to set out evidence to support this approach, and not seek to
unnecessarily delay meeting identified development needs. Stepped requirements
will need to ensure that planned housing requirements are met fully within the plan
period. In reviewing and revising policies, strategic policy-makers should ensure there is
not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may
wish to identify priority sites which can be delivered earlier in the plan period, such
as those on brownfield land and where there is supporting infrastructure in place e.g.,
transport hubs. These sites will provide additional flexibility and more certainty that
authorities will be able to demonstrate a sufficient supply of deliverable sites against the
housing requirement.” (SPRU emphasis)

There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:
• The change in housing requirement cannot be considered significant. The Council was
fully aware of these circumstances when the Local Plan 2030 was adopted with the
requirement for early review. Planning for a difference in the annual requirement of
around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest
change in the context of a recently adopted Local Plan that should maintain a minimum
rolling supply against the OAN figure
• The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that
problem
• The current Local Plan 2030 housing trajectory provides for no flexibility or certainty
(particularly given issues with Neighbourhood Plans and Town Centre sites). The
Council’s Preferred Options provide no resolution to this.
• The use of a stepped trajectory will not ensure needs are met in full. There will be a
substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the
latest information regarding supply). A reliance on large-scale strategic sites beyond
2030, for which there is a poor record of success in the borough in terms of timescales
and rates of delivery, does not provide a reasonable prospect of development in
accordance with PPG ID: 68-019-20190722)

Those issues relating to the current Local Plan 2030 mean that there is no prospect
whatsoever that extant commitments and allocations alone would allow the Council to
demonstrate a five year supply of deliverable sites based on the calculation of minimum
annual local housing need upon adoption of the Local Plan 2030.
Our analysis demonstrates that the Council’s proposed approach to rely on a stepped
trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon
adoption of the Local Plan 2040 without significant support to prioritise the early delivery of
additional sites.