Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9782

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
Policy DS3(S) provides insufficient explanation as to the proposed minimum number of new dwellings and it does not a clear or accurate explanation.
We consider that Policy DS3(S) 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.
The proposed policy does not demonstrate that it has satisfied paragraph 61 of the NPPF which requires strategic policies to determine the minimum number of homes needed, informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
Paragraph 4.7 of the emerging local plan states that as a result of the government’s recent revisions to the standard method, the housing figure for Bedford Borough is 1,355 dwellings per year, giving a total of 27,100 dwellings for the 20 year period from 2020 to 2040. The proposed policy is only to plan for this minimum, nothing more and hence there is no flexibility in this due to the absence of an appropriate buffer. We would expect to see a 10-15% buffer put in place, as this is often the accepted buffer for such matters. The strategy is not sound because it relies entirely on all of the strategic and non-strategic sites delivering within the plan period as envisaged, despite there being critical decisions yet to be made on masterplanning, infrastructure delivery, etc in the surrounding areas.
There is no explanation as to the options assessed for preparation of a local plan which includes a housing delivery figure above a minimum required under the standard method. Housing delivery in the Borough has already exceeded the annual minimum provision proposed under Policy DS3(S) in the periods 2020/21 to 2024/25 and 2025/26 to 2029/2030. Therefore this is a proposed local plan, which in respect of housing growth, shows a reduction in growth. It is a slowing-up in growth and this will be reflected in terms of investment including in infrastructure in comparison to recent delivery.
This is not a sound approach to take. Much is made of the Oxford-Cambridge Arc within the draft local plan but not when it comes to planning for the amount and timing for housing growth which seems to want to slow-up delivery and push it back later into the proposed plan period, by which time there would have to have been at least one further partial or full review of this emerging local plan.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. The proposed local plan includes new settlements but it does not look ahead over the longer timescale.
The policy and the plan overall does not provide for the paragraph 69 NPPF requirement for land to accommodate at least 10% of the housing requirement on sites no larger than one hectare or else shown through policy why there are strong reasons why this target cannot be achieved. We mention this because it is a matter for examination into the plan under the tests of soundness being consistent with national policy.
The table under Policy DS3(S) is not accurate in that the numbers within the rows do not add up to the total. This might be a typographical error but either way it needs to be accurate.
There is no justification given for the proposed stepped trajectory and insufficient explanation of a trajectory. Paragraph 74 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the plan period, and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites. We consider it is appropriate to set out the anticipated rate of development for all proposed specific sites within the emerging local plan because without this the process is not transparent or measurable. This approach means they will not be meeting their housing need (including affordable housing) in the early years of the plan because of the stepped trajectory.