Comment

Representation ID: 9577

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM3(S) (Housing mix) requires new housing developments to provide a mix of
dwelling size and type to meet the identified needs of the community including families with
children, older people, people wishing to build their own homes and people with disabilities
and special needs in accordance with the Council’s current Local Housing
Needs Assessment. Clearly each scheme should be considered on its own merits and it is
unrealistic that all of these unit types could be applied to all development proposals. Whilst it
is recognised that the subsequent paragraphs provide additional detail, it would be helpful to
add ‘as appropriate’ to the paragraph, as this could be considered ambiguous as currently
worded. Referring back to our earlier comments about optimising housing delivery to meet
housing need and the inherent design constraints associated with urban, brownfield
redevelopment, flexibility on housing mix policies is important.
Draft Policy DM3(S) goes on to state that ‘All developments of 500 dwellings or more in
suitable locations, will be required to include self-contained housing designed to meet the
needs of older persons, and / or supported living accommodation in accordance with the
Council’s most up to date statement of need on older person’s accommodation.’
L&Q has an extra care and support arm, L&Q Living, which manages homes for our most
vulnerable residents. In our experience, extra care and sheltered accommodation is typically
brought forward as independent developments i.e. not part of a wider scheme with private,
intermediate and other affordable tenures. Whilst we do not object in principle to Policy
DM3(S) we would ask for flexibility in discussions around this requirement to ensure that extra
care and sheltered accommodation is being delivered in the right locations and for the right
end users. Also, we feel it is important that the Council’s preferred market and affordable unit
mix (and older persons, and / or supported living accommodation as a proportion of overall
housing need) need for is clearly set out. In L&Q’s view the Bedford Borough Local Housing
Needs Assessment (April 2022 Update) does not present this information in a clear way.
Draft Policy DM3(S) goes on to state ‘All developments of 100 dwellings or more in suitable
locations, will be required to include specialist housing designed to meet the needs of those
with a learning disability or mental health need in accordance with the Council’s most up to
date statement of need.’
Whilst there is no objection to the aspirations of this policy, it is important that the Council’s
requirement for specialist housing need (as a proportion of overall housing) for is clearly set
out. In L&Q’s view the Bedford Borough Local Housing Needs Assessment (April 2022
Update) does not present this information in a clear way. We would also query what constitutes
a design that meets the needs of those with learning disability or mental health need and would
welcome some guidance on this. As we have mentioned earlier in this letter, flexibility is
required around competing design and space demands to ensure schemes are deliverable
and viable.