Comment

Representation ID: 9946

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DS3 (Amount and Timing of Housing Growth) states that a provision of 27,100 new dwellings will be stepped as follows:
[table in local plan policy DS3(S) inserted]
In order to support the policy, a stepped trajectory topic paper has been published as part of the Council’s evidence base, which seeks to illustrate why a stepped trajectory is justified. The paper states that the BBLP2040 requires a stepped trajectory as a result of the Standard method, which requires a 40% increase in the Borough’s housing delivery rate, when compared to the Local Plan 2030. The local plan strategy of an urban focus with rail-based growth is also set out as a factor, as it necessitates the delivery of large strategic sites with longer lead in times.
Whilst these factors are acknowledged, the principle of a stepped housing trajectory is not accepted. The Council should be ensuring that the housing needs are met at a consistent rate throughout the plan rather than deferring until later in the plan period, particularly when the resultant impact will be delivery later in the plan period of a scale which has not been achieved in the Borough in the recent past.
We agree that larger sites take significant lengths of time before development commences and optimum rates of housing delivery are achieved. The PPG provides further information on when a stepped housing requirement may be appropriate for plan-making (Paragraph: 021 Reference ID: 68-021-20190722). Whilst it acknowledges the reasons set out within the background paper, it states that stepped requirements will still need to ensure that planned housing requirements are met fully within the plan period, in order to avoid delays in meeting identified development needs.
Due to the uncertainties which surround the delivery of the major infrastructure on which the large strategic sites depend and given the viability challenges highlighted on some of the allocated ‘urban’ sites, the Local Plan should allocate sufficient smaller non-strategic sized sites in locations other than Bedford urban area to complement larger sites and to ensure HLS in the early to mid-term. In order for the strategy to be ‘sound’, the Council should consider sustainable sites (without extensive infrastructure requirements) that can come forward earlier in the plan period and take pressure off the delivery of a high number of sites and homes between 2030 and 2040 (especially those reliant on the delivery of infrastructure or a high level of enabling works that still have uncertainties and may be subject to delay). The Council recognises that meeting an increased minimum requirement of housing (compared to the adopted Local Plan 2030) will bring with it considerable challenges, and therefore must ensure that they also bring forward suitable and sustainable sites with less reliance on large scale infrastructure projects which are less likely to come froward within the timescale envisaged.