Of the minimum 27,100 new dwellings to be built across the plan period, 10,850 are to be distributed to the South of Bedford and at Little Barford as part of the new settlement development strategy which represents a staggering 40% of the local housing need figure. A further 1,500 dwellings are to be delivered as part of the strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale, which increases this proportion to 45.5% - almost half of the housing target for the plan period.
Housing is thus primarily intended to be supplied via large sites – more specifically, the strategic and new locations for growth – and LP2040 makes very little provision for allocated housing sites elsewhere. Consequently, this would not provide a sufficient mix of sites.
As a result, a number of small to medium scale developers would struggle to bring forward housing, if at all, of varying sizes, types and tenures in rural areas given the very restrictive policies under the currently proposed Plan for rural settlements. Indeed, there are a number of sites, such as one put forward by our client in Bromham, that is of an appropriate scale so as to make provision of various types and tenures, yet would not be permissible.
Paragraph 72(c) requires that LPAs, in identifying suitable locations for large scale development, should ensure the needs of different groups in the community will be provided. However, the lack of small, rural site allocations indicates that the needs of all groups in many rural communities will not be met. While large scale development may offer significant benefits, they should not be the only form of growth.
The Council has not set out any contingency plan in the event that these above sites do not deliver as expected. This is not good planning and means the LP2040 cannot be consider to be positively prepared, justified, or effective.
A stepped trajectory therefore, as it is currently proposed by the Council due to the above distribution of growth, would have a significant impact on the level of housing supply and delivery in the short run; it would be unable to meet the needs of residents upon adoption, many of whom require suitable housing now, thereby introducing a protracted period of time where there is to be a dismal supply of housing to facilitate growth in the plan area and inevitably worsening affordability issues in the borough. This significant concern is further deepened 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.
In its heavy reliance on strategic sites, the Council also runs the risk of not meeting the increase in supply and delivery at the appropriate time and in the long run, which would have a detrimental impact on being able to meet housing need for the plan period. The expected housing supply per year at the higher end of the stepped trajectory is invariably above the average supply of housing per year at a sustained trajectory; therefore, a shortfall in supply in even one year at the higher trajectory would put the Council in a very precarious position of being unlikely to deliver it minimum targets as it has been demonstrated there are greater risks in delivering larger sites. There would be little, if any, opportunity to rectify any shortfall in housing supply and delivery. For these reasons the Plan is not considered to be a sound one.
It is suggested that the Council should make suitable allocations for smaller sites across the borough in further consultation with developers so that they may be considered as specific, deliverable sites that can and will contribute to the housing supply upon adoption. Certainly, smaller sites face less risk of non or under deliverability and would present a step change in its current approach which is likely primed to fail.
There is clearly not a sufficient variety of allocated sites in terms of location, types and time horizons. There is no provision being made for rural housing contrary to Policy 79 of the NPPF, which requires:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Certainly, three of the identified locations for growth form a very substantial proportion of housing land, with very little regard hard to (prospective) rural residents and businesses. The Council have not demonstrated in any way how or why smaller allocations in smaller settlements, particularly rural settlements, have not been made and therefore fails to address their potential growth in the Plan.
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.