Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9521

Received: 27/07/2022

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

2.36 Emerging policy DS5 sets out where growth is to be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040.
2.37 Emerging policy DS5(S) sets out the following distribution of housing growth: (table included in the original)
2.38 As detailed in response to Policy DS2 it is considered that the Council’s preferred strategy is over reliant on strategic sites and new settlements and is not sound. The approach proposed risks the delivery of the Plan as it is highly vulnerable to delayed or non-delivery. If one of the strategic sites does not deliver than the Plan will fail. Further, the approach adopted by the Council does not provide for choice and competition in the housing land market, which is likely to result in land price inflation given most the new housing is under the control of a limited number of landowners. Moreover, it largely rules out developments being brought forward by SME housebuilders, instead creating a monopoly of sites which can likely only be delivered by the larger housebuilders who will benefit from the economies of scale. As a result, there will also be a limited variety of houses realising to the market concurrently, slowing market absorption which will have high consequences in the latter years of the Plan period in terms of satisfying the Housing Delivery Test or demonstrating a five-year housing land supply.
2.39 The Plan states that there will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres however, no new/additional allocations are made in these villages in the Local Plan 2040.
2.40 The Plan instead advises that some Parish Councils may choose to allocate further sites for development in their Neighbourhood Plan; there is no requirement for this.
2.41 This absence of small and medium growth in the rural villages misses an opportunity to delivery some of the housing requirement earlier on in the Plan period, rather than relying on some 10,000 dwellings to be delivered through new settlements which are significantly reliant on the delivery of large-scale infrastructure. As detailed in response to PolicyDS3 it is not an appropriate strategy to place such a reliance on strategic infrastructure to deliver such a large proportion of a housing need.
2.42 The evidence base which supported the previous Local Plan 2030 and initial drafts of that Local Plan confirmed that there is capacity within the smaller settlements to deliver a higher quantum of growth than was adopted through the Plan (up to 150 dwellings in each settlement rather than the 25 – 50 dwellings detailed within the Plan). The Plan states that it is not possible to provide additional housing in the early years of the Plan period, but this is not justified. Its own evidence has clearly demonstrated that settlements such as Willington are suitable for a higher quantum of growth than currently being delivered under the adopted Plan.
2.43 The distribution of growth within the LP2040 is not effective. As detailed in response to Policy DS3, such a reliance on strategic sites is not be deliverable over the Plan period (it is already noted in policy DS5(S) that 400 dwellings will be delivered beyond the plan period, before accounting for any delays in site assembly, unlocking and delivering the required infrastructure, and actually delivering homes on sites included within the plan period).