Comment

Representation ID: 9661

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DM1(S) is supported with reservations regarding the soundness of the policy. It is not positively prepared as it makes no reference to developments of 100% affordable housing or allow for flexibility for developments to come forward with a specific type of affordable housing to meet an identified need.

The Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update (Supporting Document ID 19), in Figure 9 sets out a total affordable housing requirement for 1-bedroom affordable dwellings of 1,218 units for the period 2020 to 2040 including 936 units for those unable to afford market rents.

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.

Without prejudice to the prospect of our client providing a more detailed assessment of affordable housing need as part of a review of the Council’s own evidence, it is evident from its own position that the identified annual need for around 345 units is substantially below current levels of delivery (192 units for 2020/21 within the Council’s most recent interim Housing Monitoring Report) or secured as part of new permissions (150 units) over the same period. This needs to be viewed in context of the substantial current identified unmet affordable housing need recognised in the Council’s own LHNA (1,419 units unable to afford rents – see LHNA Addendum Figure 4) and the implications of the Council’s proposed stepped trajectory in delaying future needs associated with meeting local housing need in full (see separate representations to Policy DS3(S)).

Schemes making provision for a higher proportion (including 100%) of affordable housing provision early within the plan period, and specifically where in highly sustainable urban locations consistent with the Council’s wider strategy, should be expressly supported in the policies of the Local Plan 2040.

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. Draft Policy DM1(S) is not effective as it does not account for developments that may provide a higher proportion of affordable homes than the 30% provision set out and contribute towards meeting identified affordable housing needs earlier within the proposed plan period.

The reference and requirement within draft Policy DM1(S) for First Homes is not positively prepared and not effective as no provision is made for any exceptions to this policy requirement. The proposed development at the Land at Bedford Heights proposes 100% affordable, 1-bed dwellings to meet a specialist form of housing that is otherwise in short supply and which caters for a specific need that is not generally met as a proportion of the housing mix secured via conventional planning obligations for affordable housing. Draft Policy DM1(S) does not allow for this situation and does not therefore accord with para.63 b) of the NPPF to contribute to the objective of creating mixed and balanced communities.

The draft Policy also does not reflect the NPPF para 72 that supports the development of entry-level exception sites. The Council’s Housing Strategy 2021-26 echoes this support for schemes in excess of policy compliant affordable housing at para’s 6.3.6, page 41 and 6.4.12, page 45. This support is not reflected in the draft Policy. As such the Council’s Housing Strategy should be referred to within the supporting text to Policy DM1(S) where this would encourage a positively prepared approach that supports opportunities to meet affordable housing needs in full.