Comment

Representation ID: 9664

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DS3(S) is supported with reservations regarding the soundness of the policy.

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

The Council’s delivery timeframes and capacity assumptions in relation to our client’s site are incorrect. We do not, as a matter of principle, support the Council relying on a stepped trajectory as it delays meeting the identified minimum annual local housing needs for the Borough, particularly those relating to affordable housing. Suitable sites in the urban area such as our client’s site at Bedford Heights should be prioritised. This is mandated by Planning Practice Guidance ID: 68-021-20190722. In the Council’s circumstances it is essential that its assumptions regarding housing land supply are informed by developer engagement and reflect realistic details in relation to lead-in and build out rates (ID: 3-022-20190722). Fundamental shortcomings in the Council’s evidence base relating to our client’s site mean we must object to Supporting Document 27 – Stepped Housing Trajectory Topic Paper.

This shows an estimated capacity for the site of 15 units to be delivered in 2026/27 which is not justified, positively prepared and not consistent with national policy.

The site for the draft allocation HOU10 is shown on the revised Map 1 (Supporting Document 52 – Changes to Policies Map) however no evidence has been provided to justify the capacity of the site based on site area. Supporting Document 9 – Development Strategy Topic Paper May 2022 sets out that Bedford Heights draft allocation HOU10 is allocated as it is within the urban area. It is acknowledged that some urban sites are complex and may therefore result in a later delivery but these related constraints are not applicable to our client’s land, as outlined below.

Supporting Document 14 – Housing and Employment Land Availability Assessment and Site Assessments includes within Appendix 5 the Bedford Heights Call for Sites report extract (ID:7412). This highlights comments from key consultees but raises no significant issues that would restrict delivery of the site for residential development before 2026/27.

Details of the 15no. unit capacity estimate are unsourced. The Council’s estimates does 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) for the site does 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.

A planning application is currently being prepared and all required technical reports being undertaken to meet all policy requirements. The application is to be submitted in Q3 of 2022/23 and it would be likely that development could commence on site in 2023. With a modular construction methodology and due to the limited scale of the development this site could realistically deliver the units in 2023/24.