Comment

Representation ID: 9655

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DM3(S) is supported with reservations regarding the soundness of the policy. It is noted that the policy varies only minimally from the existing Local Plan Policy 59S Housing Mix.

The proposed development upon the Land at Bedford Heights (HOU10) is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Verve Developments Ltd acquired the wider Bedford Heights site in 2014. Verve Developments Ltd have a long-standing objective of providing housing for those with specific housing needs as part of a longer-term legacy. A partnership has been formed with IMPAKT Housing and Support to provide a small-scale development aimed at providing semi-independent housing with arm’s length support, along with some on-site communal facilities for those with housing needs and to tie this with opportunities for training and employment.

Draft Policy DM3(S) references the current Local Housing Needs Assessment amongst other current assessments of specific housing need and makes reference to evidence in respect of the needs of other specialist groups. Flexibility should be incorporated into the draft policy to allow for a more limited provision of size and type of affordable housing when the specific need can be evidenced. For this reason, the draft policy is not positively prepared and not effective.
As set out within the draft policy DM3(S), the Council anticipates all of its housing needs of different groups being met through all new housing development. In practice this will necessitate substantial elements of the needs of different groups being provided as a proportion of large-scale strategic developments outside of the urban area and outside of existing settlements (including proposed new settlements) where delivery is deferred until later in the plan period. The proposed development for the site is of 36, 1-bed affordable units and will address a substantial current need as outlined below.

The Council’s Interim Housing Monitoring Report (2020-21) shows that a net total of 192 affordable housing units have been completed during this time. These figures are not broken down into dwelling size and bedroom numbers.

Proposed development schemes seeking to meet an identified specialist housing need should be supported in principle. Where the mix of size and type is meeting a specific and evidenced need this should be supported and the policy should reflect this to allow the plan to positively respond to future proposals. As currently drafted it is not positively prepared in this regard.

The inclusion of accessible and adaptable dwellings provision through meeting M4(2) and (3) requirements drafted in Policy DM3(S) is supported. The proposed development will look to meet these requirements.

The proposed development would contribute towards the Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update, which in Figure 9 sets out a total affordable housing requirement for 1 bedroom affordable dwellings of 1,218.

The Council’s Housing Strategy 2021-2026 refers to identifying other vulnerable groups of people’s housing needs (8.3.2) and refers to facilitating opportunities to deliver supported housing needs although it does not identify a specific figure for the needs of these groups. As such, this is an important component of housing need not acknowledged in the first paragraph of Policy DM3(S) and a corresponding reference should be provided in the supporting text of the policy.

New specialist housing is referred to in the Council’s Local Housing Needs Assessment which includes supported housing. The glossary to this document refers to the Homes England identification of broad client groups for this type of housing - Capital Funding Guide – 3. Specialist Homes – Guidance – GOV.UK (www.gov.uk) Section 2.3.4 of this document is repeated below : -
1. Purpose-designed supported housing for disabled and vulnerable people
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features. There must be support services provided by the landlord or another organisation. As a minimum, a building or scheme must have the following:
Facilities: The scheme or main building must have basic facilities of a laundry for residents or washing machines in living units provided by the landlord and must also have a communal lounge
Design features: The entrance area into the building, communal areas and some living units must be designed to wheelchair user standards
2. Purpose-designed housing for disabled and vulnerable people with access to support
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features, as per definition 1 above, but without the requirement for support services to be provided on site. Tenants must instead have access to support and a process be in place to assist in accessing and/or signposting them to the support services that they need.
The proposed development would assist in meeting the needs of vulnerable people who have and are on a journey to independent living with arm’s length support provided, which is a well understood component of housing need that meets specific design requirements.

There is, however, no need figure set out within the LHNA document or within the draft Policy and this presents a clear limitation on how proposals to meet this important component of housing need should be assessed. In practice, as demonstrated by our client’s proposals and the expected profile of future occupiers, the majority of requirements for such accommodation are for one-bed properties.

Draft Policy DM3(S) does not make specific reference or recognise that development may come forward, as proposed at Bedford Heights, that require specific design features and access to support services in response to these needs and should accordingly be assessed favourably in-line with meeting the housing needs of different groups.