Object

Representation ID: 9783

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy and DS3(S) Amount and Timing of Housing Growth.
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 provide an explanation of the individual sites forecasted for delivery or the overall amount. There is no clarity or transparency on the dwelling numbers. For example, there is a figure of 1,200 dwellings within the urban area but no break-down of
what is included within this. This means the reader has to look in detail at the individual sites being proposed to see if it is possible to work-out what the quantum is, although this is not possible for all of the sites.
There is no explanation of a buffer within the table under Policy DS3(S) i.e. where does any buffer sit and there is no statement that all of the dwellings are minimum.
There is no figure or break-down given for the remaining rural area/villages and not explanation of the development beyond the plan period. Development beyond the plan period should not be in a table which is meant to provide a breakdown of sites intended to deliver at least the minimum housing requirements within the 2040 plan period. The table within the policy is not user-friendly and it does not pass the tests of soundness under the NPPF.
We question whether the number of dwellings identified for sites is achievable for example whether the potential dwelling yield at Little Barford and south of Bedford are achievable. The potential delivery estimates within the table under Policy DS3(S) is ambitious at least and
possibly not deliverable. This is noted in further detail within the response to Policy DS2(S).