Comment

Representation ID: 9875

Received: 28/07/2022

Respondent: Taylor Wimpey

Our main area of concern is in relation to the approach that has underpinned the development strategy set out in Policy DS(2) and the potential implications that this will have.
As part of their proposed development strategy, the Council have attempted to focus new housing within the existing urban area of Bedford and this is in keeping with the principle of sustainable development as stipulated in the National Planning Policy Framework (NPPF) (2021). However, as evidenced by the Call for Sites process, there are a limited number of available sites within the urban area and the Council have therefore attempted to identify sustainable locations for residential growth elsewhere, in particular, through the provision of large, strategic allocations.
Whilst Taylor Wimpey recognise that large, strategic sites have a key role to play in a development strategy, we consider that the growth strategy proposed by Bedford Borough Council places an over reliance on large allocations. This is to the extent that there are four new large settlements or significant urban extensions proposed as part of the Local Plan Development Strategy: Shortstown, Kempston Hardwick, Gibraltar Corner and Little Barford and no small/medium sized sites, aside from existing commitments. This will have a significant impact on the ability of the Plan to support the delivery of homes in a timely manner.
The focus on large settlements/urban extensions will have a detrimental impact on the ability of the Council to meet housing requirements in the short to medium term, even with a stepped trajectory (discussed further below). This to the extent that, we don’t believe that the Council will be able to demonstrate a deliverable five-year housing land supply on adoption of the plan and potentially beyond.
Proposing allocations in the more sustainable villages in the 2040 Review would have gone a long way in terms of bolstering the short-medium term housing land supply position, which is currently lacking.
The methodology and evidence underpinning the decision to exclude the villages is poorly justified in both the Sustainability Appraisal and the Development Strategy and Site Selection Topic Paper.
The topic paper states that when considering development options: ‘The worst performing component is the village related growth component. It is likely to have a more negative effect than the other components, particularly in relation to reducing carbon dioxide emissions, protecting water resources, and reducing the need to travel and promoting sustainable modes of travel. It is likely to have fewer positive effects than any of the other components of growth.’
However, the assessment criteria used prior to the Regulation 18 consultation process requires scrutiny. Whilst it is important to give consideration to the key areas of ‘Greener’, ‘More Accessible’, ‘More Prosperous’ and ‘Better Places’, the key practical matter of the deliverability of the strategy as a whole and issues that might result from opting for different options e.g. land assembly, viability, timescales, deliverability, previously developed land, site-specific benefits, infrastructure, etc appears to have been ignored. Had these matters been considered in more detail it is likely that additional growth in villages would have been seen as a more favourable option. Following the Regulation 18 consultation, a secondary round of work to support the development strategy was undertaken, however this also neglected the majority of these key considerations.
Linked to the above, the Council have failed to plan for 10% of their housing requirement being delivered on sites of 1ha or less as per the requirement of paragraph 69 of the NPPF. The Council, in their Small Sites Topic Paper, state that they consider that they will deliver well in excess of what is required by the NPPF through windfall development and neighbourhood plans, however the approach taken is not consistent with the NPPF which states that this provision should be identified in either the local plan or in a brownfield register. The purpose of this national policy is to provide the certainty through an allocation in a local plan.
Additionally, as is touched on further below, in our view, the anticipated delivery rates attached to the large allocations conflicts with typical rates for comparable sites. We consider that the Council have been overoptimistic in terms of the output rate of sites both in terms of average and peak delivery rates. For example, at both Kempston Hardwick and Little Barford, over the final 10 years of the plan, it is stated that these sites will deliver on average 380 dwellings a year and have a peak delivery rate of 600 homes between 2037/38-2039/40. The justification for these delivery rates is not provided and they appear high compared to evidence from similar scale schemes elsewhere (see Lichfields’ Start to Finish report 2nd edition Feb 2020 for a comparison). The housing trajectory should be amended to reflect evidence on delivery rates. When this adjustment is made, the Council will find that forecast housing delivery will fall short of that which is required to meet the housing requirement., meaning the development strategy set out in policy DS2 is unsound.
Ultimately, it is clear that no real consideration was given as to whether the villages in Bedford Borough can or should form part of the development strategy. Given the issues associated with the development strategy identified above we consider that, as proposed, it cannot be relied upon to deliver the identified housing requirement and is therefore unsound in its current form. This can only be remedied through the consideration of a more dispersed pattern of growth an allocations in sustainable rural settlements, such as Wilstead and Willington.