Landcrest support the aims of the LP2040 in meeting the local housing need figure derived from the standard methodology (SM) as set out national policy which is identified at 27,100 dwellings across the plan period. However, the proposition for stepped trajectory raises serious concerns about the commitment to real growth when it is needed most – right now. This is most evident when consideration is given to the fact that the LP2030 had required an immediate review of its strategic policies as per Policy 1, the Council being fully aware of its need to meet higher growth levels in the near future due to taking advantage of transitional arrangements at that point in time, to only continue now in delaying meeting its housing need via stepped trajectory. The Standard Methodology (SM) figure for the Borough has not changed considerably since it was first introduced in 2018 and is much higher than the housing target in the LP2030 as acknowledged by the Council. There is thus a genuine concern that this authority is not fully committed to exploring all avenues for growth for real people across the Borough in real need now.
This is in the context that Bedford currently faces increasing house prices and increasing monthly rents. In respect of house prices, the average house price paid in Bedford in the final quarter of 2021 is over £350,000 according to the Office for National Statistics (ONS). When compared to an average income of approximately £33,400 according to ONS figures, an average priced home in Bedford costs over 10 times more than an average household earns, meaning affordability is a significant barrier to many people wishing to acquire a suitable home. The lower quartile house price ratio stands at a similarly staggering 10.43 times household income as per ONS data, and means that many people at the lower end of the market are pushed into the private rented sector, often with poorer living conditions and insecure tenancies.
This situation is fundamentally against Government ambitions to make housing more affordable for everyone, which is why affordability remains a key adjustment factor in the Standard Method, and against ever increasing house prices (despite even the consequences of the current pandemic) it is only reasonably expected that the Council’s local housing need will continue to increase in future years due to this factor alone.
The consequences of this spatial strategy thus become alarmingly apparent. It is no secret that larger development proposals – such as those at the newly proposed settlements - spend a greater amount of time from planning application submission to delivery of the first dwelling that smaller sites. Furthermore, it must also be taken into account that larger sites do not, by comparison, have proportionally larger build-out rates than smaller sites which amplifies the impacts of a stepped trajectory. Specifically, the Nathaniel Lichfield & Partners’ ‘Start to Finish’ report (second edition) investigates average lead-in times and build out rates of large sites and supports the above. Of the new settlements, the report estimates a lead-in time to first delivery at over 8 years based on the scale of growth proposed from the time of an application being submitted. It is evident, then, that the stepped trajectory is derived from the spatial strategy which has at its heart these new settlements for growth. Furthermore, the report identifies that build out rates are estimated to be as no higher than approximately 160 dwellings per year on average for the settlements that have a minimum housing provision of over 2,000.
It follows, then, that a stepped trajectory cannot be appropriate nor justified. The lead-in times and build-out rates of large scale strategic sites are relatively poor. The lack of small and medium sites allocated in LP2040 exacerbates the situation as any complications or delays for development in these locations will have profound consequences for the Council’s housing land supply over the plan period.
All of the above reinforces the critical need to include some smaller and medium sized allocations into the Plan to provide shorter term delivery early in the Plan period. Without this the Plan cannot be considered an appropriate strategy, taking into account the reasonable alternatives to include growth at Key Service Centres. Instead, urban based growth would starve more rural locations of much needed growth -housing or employment – while in turn risking the build-up of urban sprawl.
Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Bromham which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future.
In incorporating dispersed growth as part of a strategy, many rural communities such as Bromham would continue to be well-connected places without experiencing overdevelopment. Dispersing growth further allows for rural centres to retain and enhance their vitality and improve the quality of living in these areas in line with what they are capable of accommodating thereby securing a more vibrant Borough as compared to a single, densified urban area that rural communities become entirely dependent upon.
An allocation such as that proposed at Bromham by our client, which has previously had a recommendation for approval by Officers for 80 dwellings, would provide a significant, and suitable, opportunity for the village to grow and thrive, and would also support local services and infrastructure, to include those in nearby villages, and would have made an important contribution to the Council’s housing land supply and targets in the earlier years of the plan period which would alleviate the dependency on large scale strategic sites for growth.