Object

Representation ID: 9759

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As it stands the plan in our view is not sound on the following tests under paragraph 35 of the
National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
Whilst we agree that all homes should be delivered to a high standard and be of good quality, we also consider that space standards can, in some instances, have a negative impact by reducing customer choice and increasing affordability issues. Developers tend to provide entry-level one and two-bedroom properties which may not always meet the optional nationally described space standards, but which would be affordable for the number of required bedrooms.
Given that no evidence is presented with regard to the need for space standards, the policy is unjustified, and as such, unsound.