Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9976

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy DS5(S) Distribution of Growth
This policy sets out the components of the spatial strategy. The Local Plan 2040 makes allocations for up to 13,550 new homes within the plan period, with 400 homes expected beyond the plan period.
Gladman has already submitted detailed commentary on the spatial strategy to policy DS2 and the SA and so will not rehearse these points again here.
The 13,550 new homes combined with commitments, windfall allowance and completions of 14,824 dwellings this is a total of 27,834 against the requirement of 27,100. This only represents a flexibility factor of 2.7% above the minimum housing requirement, or just over one year’s delivery at either Garden Settlement.
To safeguard any slippage in the anticipated trajectory of these large strategic sites the over-provision in the plan period should be increased. There is no hard and fast rule for what this over-provision should be but, Gladman supports the Home Builders Federation’s recommendation that local plans should seek to identify sufficient deliverable sites to provide a 20% buffer between the housing requirement and supply.
Without identifying further small and medium sites to deliver in the early part of the plan period there is a real risk that the minimum housing requirement of the Local Plan will not be met.
The Councils Local Plan strategy as currently set out has insufficient flexibility to be considered sound. A minor change to the delivery timescales of one of the new settlements would see the whole plan (already significantly backloaded in terms of delivery) fail to achieve its targets.

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