Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9660

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Representation Summary:

Draft Policy HOU10 is supported with reservations regarding the soundness of the policy.

The proposed development at the Land at Bedford Heights 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.

The support for the principle of development identified by draft allocation HOU10 and supporting text at paragraph 4.64 is welcomed. Our client confirms that the area identified within the draft allocation boundary is surplus to requirements for car parking and alternative residential use in this location will not impact upon the operational requirements of the Bedford Heights site. However, our client does not support any suggestion that the area identified for allocation, or the extent of existing parking within this part of the site, should determine a capacity for development less than the 36no. units identified within its emerging proposals for development.

Draft Policy HOU10 is not positively prepared and not justified as it does not include a reference to the proposed capacity of the site (15 units) which is set out in Supporting Document 27 – Housing Trajectory. There is no recognition of different forms of developments (apartments) that could deliver a higher number of units on the site which would be a more effective and efficient form of development. Details of the 15no. unit capacity estimate are unsourced. They do not utilise the Council’s standard density multiplier of 30dph, based on the approx. 0.2ha site area, notwithstanding that our client would not agree with this assumption as it would fail to make best use of land within the urban area.

The ‘proposed use’ details within the Council’s HELAA Assessment Form (ID:7412) do recognise the suitability of flatted development in this location (30 units) and the evidence base is therefore inconsistent with details of capacity within the Housing Trajectory or Plan for Submission, albeit the HELAA fails to fully reflect the unit mix and associated capacity for emerging proposals at the site.

Two rounds of pre-application engagement have been undertaken on the proposed development of bespoke affordable housing development. Ongoing discussions and dialogue have taken place to discuss issues relating to technical comments and design aspects.

A project exhibition was hosted on the Bedford Heights site on 28th April 2022, which provided all residents with the opportunity to review the scheme and raise concerns / questions. A consultation website was also launched to allow comments to be made. Discussions have also been taking place with the Council’s Housing Team.

The proposed development of 36 affordable housing units (1-bed) is a carefully designed, sustainable development.

The Key Principles of the development set out in the draft Policy are commented on below:

i. Preparation by the applicant of a masterplan and design code to be complete prior to and submitted with any planning application and to pay particular attention to the adjacent noise sources, layout and massing of the site having regard to its elevated location;

We support the principle of supporting information to demonstrate how the design of the site has evolved and full consideration has been given to key constraints of the site. The proposed development of the site by IMPAKT Housing & Support will be fully supported through a Design and Access Statement. The size of the development site is considered to be quite small for such a specific requirement for a Masterplan and Design Code and is not justified. The planning application will be prepared in accordance with national policy and best practice on design in the absence of a Local Planning Authority design code.

ii. Access from Brickhill Drive;

We support that the proposed development should provide an access from Brickhill Drive. The proposed development utilises the existing car park access from Brickhill Drive.

iii. Provision of safe pedestrian and cycle links to adjacent networks;

We support that the site should have provision of safe pedestrian and cycle links. It is well located in a sustainable position for nearby services and facilities.

The proposed development is located on an area of existing car parking. This is lightly used with significant spare capacity in the immediate and wider surrounding Bedford Heights areas.

Covered and secure and short stay cycle parking will be provided in line with Council requirements. The quantum of car parking will reflect IMPAKT Housing & Support’s experience of developing and managing similar affordable schemes through the UK. Electric vehicle charging and DDA compliant spaces will be provided in line with Council guidance.

iv. Landscaping on and around the site to soften the interface with the adjacent car park;

We support the provision of landscaping to soften the development. This is proposed to be incorporated as part of the scheme currently being prepared.

v. Financial contributions towards secondary school provision;

This requirement appears to have been applied to most of the draft housing allocation sites within the Local Plan.

Support Document 16 – Bedford Infrastructure Delivery Plan, Section 6.2 covers Secondary Education. This looks at the demand for secondary education to 2040 and makes reference to the Bedford Borough Council (2013) Planning Obligations Supplementary Planning Document that assumes there are 21 secondary school aged children for every 100 dwellings built. Within paragraph 6.2.21 reference is made to small sites being required to make CIL or S106 payments to help fund the extension of existing schools or to fund the creation of a new school in the vicinity. There is no specific reference to the type of housing developments proposed and is therefore not justified or positively prepared.

In this case the proposal is for 36 1-bed dwellings which will generate no school age children and will therefore not generate a need in secondary education infrastructure terms. The policy is not flexibly worded to allow for consideration of a range of sizes of dwellings and the different requirements of these in terms of school age children. In accordance with the proposed saved Policy 33 of the Bedford Borough Local Plan 2030 there would be no adverse impacts to secondary education required to be mitigated through the proposed development of the site in accordance with the proposed 36, 1-bed dwellings and would therefore not meet the statutory tests set out within the CIL Regulations 2010 echoed in paragraph 57 of the NPPF (2021). The draft policy criterion is therefore not consistent with national policy.

vi. Delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change;

We support this key principle and the applicant for the development has aspirations for it to be one of the highest performing developments within Bedford in respect of sustainability, adopting a fabric first approach and extensive use of renewable technology.

vii. Early engagement with Anglian Water is required in order to identify connection to water network infrastructure

We support this principle and technical liaison will take place with the applicant’s drainage engineers to establish connections and adequate provision is made for water supply and surface and foul water disposal.