Object

Representation ID: 9587

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

3.1 The spatial strategy of focusing growth in the south of Bedford area (Policy HOU12) is supported by our client. However, our client contends that the approach taken to
allocating sites and, in particular, the quantum of development allocated on certain sites is not justified nor consistent with national policy, for the following reasons.
3.2 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13, HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear understanding and expectation as to the quantum of development that the Plan is proposing in these locations.
3.3 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
3.4 What is not evident from the evidence base or the Local Plan, is the approximate developable areas and thus whether these are realistic densities. Upon examination of the Policies for each site, and the Figures in the Local Plan which accompany each, the only way to achieve all the Policy requirements, in particular the amount of open space and green infrastructure, would necessitate very high densities on the majority of these
sites (c. 50/60+ dph).
3.5 There is no evidence accompanying the Local Plan which justifies this approach; the HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which a high density would lead to, nor is there market evidence supporting housing demand for such a high quantum of small units in these locations.
3.6 This is likely to lead to future applications which either decrease the number of homes, resulting in unmet need (in terms of overall quantum and/or mix) and possibly nondelivery of key infrastructure. Alternatively, it may lead to non-delivery of green infrastructure due to pressures to deliver housing numbers.
3.7 The quantum for each allocation is not based on a proportionate or robust evidence base and are therefore not sound.