Comment

Representation ID: 9615

Received: 26/07/2022

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

We note that the growth locations are to be within the urban area, next followed by strategic locations adjacent to the urban area and which contribute to the delivery of key green infrastructure projects and at new growth locations which are focussed along the EWR/A421 transport corridor with potential for rail-based growth, especially in the south of Bedford area and a new settlement at Little Barford.

A number of allocations have come forward within the current Local Plan 2040; however, it is not currently clear how many dwellings these allocations would be able to accommodate, either in total or individually. We maintain that it is essential the Council over-allocates housing land to ensure flexibility, choice and competition in the housing market, reflecting government guidance. We maintain that a mix of smaller and medium-scale sites can be delivered at a faster rate than the larger, allocated sites. These sites, such as our clients, which were submitted in the Call for Sites exercise but not taken forward, form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow Councils to continuously maintain a healthy and constant supply of deliverable sites, especially where there has been such an increase in the housing need figure.

Our previous representations on prior consultations for the Local Plan 2040 has suggested that whilst a larger proportion of housing and employment growth should be focused on the urban area, growth should also be located within the rural areas. We note that Policy DS2(S) Spatial Strategy point xi considers that “The completion of strategic Key Service Centre and more limited Rural Service Centre residential development identified in Local Plan 2030 on sites which are allocated in neighbourhood plans and the completion of Local Plan 2030 Policy 27 Land north of School Lane, Roxton.” We maintain that development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. Alongside promoting housing, this would ensure that rural areas received an appropriate level of growth to maintain and enhance economic vitality, and the services and facilities required would be maintained. As previously highlighted, this approach would take into account Paragraph 79 of the NPPF to promote housing growth in the rural settlements of the Borough. More housing in rural areas would maintain their vitality, including the retention of services and facilities that depend on economic growth, promoting greater and more sustainable development.

The draft plan maintains its reliance on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, as highlighted in previous representations, we maintain that any delays to emerging neighbourhood plans could stall the delivery of housing within the Borough. We maintain that those which have been ‘made’ are based on the Local Plan 2030 housing need of 970 dwellings per annum; considering the significant increase in housing need, these ‘made’ neighbourhood plans are likely to require reviewing. In addition, we reiterate that Neighbourhood Plans are not subject to the same stringent examination as Local Plans, and therefore, the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.