Object

Representation ID: 9982

Received: 27/07/2022

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The spatial strategy is unsound as it is not consistent with the requirements of national policy.
3. The Council’s assessment of housing needs is consistent with the approach set out in Planning Practice Guidance and results in a minimum housing need across the plan period of 27,100 homes. In seeking to meet these needs in full the Council’s spatial strategy relies on the delivery of significant development at Kempston Hardwick (HOU14) and the new settlement at Little Barford which, together, are expected to deliver 7,200 homes over the final 10 years of the plan.
4. Whilst the HBF does not oppose either of these allocations we are concerned that the expected rates of delivery on these two allocations is overly optimistic. The Council expect both these sites to deliver 3,800 homes each between 2030/31 and 2039/40 at an average of 380 dpa, with a peak delivery rate of 600 homes between 2037/38 and 2039/40. Whilst the period between this plan being adopted and these developments commencing is broadly reasonably the average delivery rate and peak delivery rates are high compared to evidence from other similar schemes.
5. The second edition of Lichfields, Start to Finish Feb report published in 2020 provides helpful insight into expected housing trajectories for a range of schemes and we would recommend that the Council uses this evidence to reconsider its delivery trajectories. In particular we would suggest the Council considers the evidence in this report with regard to schemes of over 2,000 new homes. Table 3 of the report sets out that the mean annual delivery rate for schemes of over 2,000 homes is 160dpa, significantly lower than the Council’s expectations. However, using the mean can disguise schemes that delivered much higher rates but even here the Council’s estimates appear high with figure 3 indicating that the highest average delivery rate seen was under 300dpa.
6. With regard to peak delivery rates the report sets out in Table 5 that schemes of over 2,000 delivery rates can reach 600 dpa citing Cambourne in Cambridge as an example. However, this rate of delivery was significantly higher than other schemes and still only resulted in an average annual build out rate of 223 dpa. Therefore, whilst there may be some years where delivery of 600 dpa is possible this should be seen as an exception and as such we do not consider the delivery estimates for both the sites referred to above, which the Council expect will consistently deliver 600dpa, to be as being justified. The HBF consider it necessary to amend the trajectory for both these sites to deliver at an average rate of circa 280 dpa with a peak delivery rate of no more than 400 dpa. These are still ambitious estimates but are more aligned with the evidence.
7. Ensuring delivery estimates are reasonable is important in considering whether the strategy being proposed by the Council is sound in that it meet the key requirement set out in paragraph 11 of the NPPF that needs are met in full. Adjusting the delivery estimates on these two sites to deliver a more reasonable but still ambitious average delivery rate of 280dpa would result an under supply of 748 homes. As such the Council will need to identify additional sites in order to ensure housing needs are met in full.
8. In addition, the Council will need to ensure that there is sufficient flexibility in their land supply to guarantee the plan is deliverable across its plan period. Whilst the proposed adjustments are more realistic, they are still, as outlined above, at the upper end of what has been delivered on similar schemes elsewhere. With any large development there can be delays to commencement and slower build out rates. As such ensuring that there is sufficient supply in the early part of the plan period in order to maintain a buffer towards the end will give flexibility in the Council’s land supply and guarantee the Council can meet needs and reduce the need for future reviews.
Sites of less than 1 ha
9. One of the consequences of a spatial strategy that places its reliance on larger sites to meet needs is that there are relatively few smaller sites allocated. As the Council are aware paragraph 69 of the NPPF states that local planning authorities should: “identify through the development plan and brownfield registers land to accommodate at least 10% of their housing requirement on sites of less than 1ha”. The Council in their Small Sites Topic Paper outline in the table following paragraph that they consider that such sites will deliver well in excess of what is required by the NPPF. However, their estimates are not consistent with what is required by the NPPF. The Councill’s estimates include the likely supply from windfall and neighbourhood plans whereas the NPPF requires such sites to be identified either in the local plan or in the brownfield register. The likely supply from windfall or Neighbourhood Plans are self-evidently not identified supply and do not address the key purpose of this policy which is to provide the certainty of an allocation or permission in principle that is only available from inclusion in either the local plan or brownfield register.
10. It is important that the Council recognises that the reason behind this policy was the declining number of SME housebuilders and the Government’s recognition that if it is to achieve the overarching aims of meeting needs and providing a diverse range of housing it needs to support SME housebuilders. In seeking to ensure more small sites are allocated, sites that are more typically brought forward by SME developers, the Government is seeking to reduce the risks faced by such developers allowing the sector grow. As such the inclusion of windfall sites, which by their very definition are sites not identified by the local plan, in the estimate of delivery on small sites is inconsistent with national policy. Removing both the windfall estimate and estimate of delivery from neighbourhood plans means that delivery on sites of less than 1ha identified in with the local plan or brownfield register is 1,161 homes – some 1,549 homes short of the required level.