Comment

Representation ID: 9877

Received: 28/07/2022

Respondent: Taylor Wimpey

Policy DS5(S) sets out how the level of growth set out in policy DS3 will be distributed across Bedford Borough. Notwithstanding the points made above about the housing requirement and the overall development strategy, we have particular concerns about the distribution of growth.
The main issue is that the distribution does not appear to factor in any buffer on the supply side. The inclusion of a 10% buffer, as a minimum, should be factored into the supply of housing in order to act as a contingency for under-delivery on identified sites. This is a fairly standard approach taken with Local Plans in order to ensure that housing targets are met and that plans have flexibility built in. This would help to ensure that the requirements of paragraph 68 of the National Planning Policy Framework (NPPF) (2021), which stipulates that council’s should plan for a deliverable supply of land for years 1-5 of the plan plus an appropriate buffer to be identified, will be achieved.
Given the reliance on strategic scale sites, it is suggested that a larger buffer may be appropriate given the risk to the delivery of homes that is associated with a limited supply of large sites.
As noted above, we have a fundamental concern that by not allocating any development to sustainable rural settlements, such as Wilstead and Willington, the ability of the plan to meet its housing need in a timely manner is unduly affected. In considering the strategy in the adopted Local Plan, it was deemed appropriate and sustainable to focus growth on certain settlements. The proposed approach goes away from this without a proper justification and our view is that to be sound, further consideration needs to be given to the role that settlements such as Wilstead and Willington pay in the Local Plan.
Site Assessment Process
We would also like to re-iterate our concerns, as expressed in our Regulation 18 representation prepared by Bidwells, regarding the shortcomings of the Council’s Call for Sites Assessment Process which fed into the development strategy.
The site assessment forms lack any detailed assessment and have not been underpinned by a review of all the evidence available to the Council; colleagues in other departments (such as heritage, highways, etc.) do not appear to have been consulted as part of this process, including the development management team. When looking at the assessment of our own sites in both Wilstead and Willington, the information stated conflicts with information provided by ourselves and the conclusions reached by Council Officers on recent planning applications (on important matters such as previously developed land, heritage, etc). These forms also do not consider the potential benefits that sites could offer which should be a consideration in the suitability and sustainability of sites.
Given our aforementioned concerns in relation to the development strategy, we are concerned that a large number of sites were discarded on the basis of their conflict with the development strategy as part of this assessment process. The site assessment work should feed into the formulation of a development strategy - it should be a two-way process. However, from the Sustainability Appraisal and Topic Paper, it instead seems that the site assessment work was undertaken in a bubble and the information was only used to fit an independently developed strategy.
General Compilation
The Council have failed to properly collate previous planning policies into a single, clear planning document and instead simply save policies from previous Development Plan documents.
The emerging development plan comprises policies from the document itself (Local Plan 2040), the Local Plan 2002, Bedfordshire and Luton Minerals and Waste Local Plan 2005, the Allocations and Designations Local Plan 2013 and the Local Plan 2030.
Paragraph 16 of the NPPF is clear that plans should ‘contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals’, as well as ‘be accessible through the use of digital tools to assist public involvement and policy presentation’.
With how the plan is currently drafted, the requirements of paragraph 16 have not been met in that this document is not accessible to the public; relevant information is spread over six development plan documents and an individual will have to find a table included in an Appendix to understand what policy to apply. The plan is not accessible and it therefore conflicts with national policy.