Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9974

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy DS3(S) Amount and Timing of Housing Growth
The Local Plan is proposing to set a housing requirement of 27,100 between 2020 and 2040. This equates to an annual housing target of 1,355 using the standard methodology for calculating housing needs.
PPG clearly states that the standard methodology is merely the starting point for calculating housing need and only provides the minimum number of homes needed to meet the demographic baseline of housing needs. It is important that the housing needs of Bedford are not under-estimated.
Further consideration of the local circumstances of the area and the aspirations the Council wishes to achieve should be considered in determining the number of homes needed. This can include resolving historic housing under delivery, increasing economic output of the area, boosting affordable housing supply and the delivery of key infrastructure projects. Consideration should also be given as to whether the local authority is able to assist neighbouring authorities with their unmet housing needs. All of these factors should ultimately inform the final housing requirement for the Plan.
In the context of Bedford, the aspirations and implications of the Oxford-Cambridge Arc should not be under-estimated. Sitting centrally within the arc the potential economic boost of two planned new stations along the East West Rail (EWR) could have significant implications for economic growth and housing need. It is important that employment growth and housing growth are aligned so as to ensure unsustainable commuting patterns are not formed. However, it must also be noted that at the time of writing there are emerging doubts about the EWR proposals through the borough.
Stepped Trajectory
The Council are proposing to use a stepped trajectory for the delivery of housing. Continuing the housing target (970) of the Local Plan 2030 for the first five period, a minimal increase to 1,050 for the second five year period and a significant increase from 2030 onwards to 1,700 dwellings per annum when the strategic infrastructure, that a number of allocations are reliant on, is scheduled to be completed. Doubts have recently emerged around the Government’s commitment to this infrastructure and this could have serious implications for the plan as a whole.
Gladman strongly object to this approach. Whilst we recognise that the increase from the adopted housing target to the use of the standard methodology is a large increase, this is mainly due to the affordability adjustment of the calculation due to the inherent unaffordability of the borough. Seeking to defer meeting the needs established using the standard methodology is only likely to compound affordability issues and does not represent a positively prepared local plan. More should be done to address this increase in the short term. The apparent need for the stepped trajectory is a due to a deliberate choice from the Council to favour a strategy of two Garden Settlements, expected to deliver in the later stages of the plan period. Whilst these Garden Settlements are linked to large scale strategic infrastructure projects the rate of delivery expected on these sites is very ambitious in the latter part of the plan period and there is scope for this to roll on beyond the plan period.
Delivery rates reaching up to 600 dwellings on a single development for, a number of years is highly unlikely to be achievable, the Local Plan trajectory proposes this across two sites at the same time. Evidence from Lichfield’s second edition of the Start to Finish report3 on build out rates indicates that the average build out rate for sites larger than 2,000 dwellings is 181 dwellings per annum on average across the whole life of the development. Whilst recognising that build out rates can vary due to a number of conditions, 7 continuous years of delivery in excess of these figures and in 4 of years over double this rate is unprecedented.
Most of the housing delivery is proposed on these two sites in the latter stages of the plan period and by this stage it will be Impossible to address the failures of the strategy. Using a more realistic expectation around delivery rates on these sites would mean that the Council will not meet the minimum housing requirement. A significant failing of the proposed strategy.
This would also be likely to adversely affect the vitality and viability of services in existing settlements and result in a lack of housing choice in the market. It would also be difficult to accommodate changes in demand for certain types of development/services required over the very long period being committed to within the current strategy.

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