Development Strategy Topic Paper

Comment

Representation ID: 9357

Received: 28/07/2022

Respondent: Mr Glenn Hall

Less emphasis on EWR delivering massive growth and investment, as it is unlikely to happen

Comment

Representation ID: 9710

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

4.5 The evidence underpinning these policies has also failed to consider all reasonable alternatives, including a larger amount of employment land27. The SA’s assessment of the employment land options is flawed. It considers three options: C) 90Ha (more high density office development); D) 142Ha; and E) 206Ha (lower density office/ business park dev with more warehousing). These options do not appear to be consistent with those presented in the Employment
27 We note that the employment land options considered in the Sustainability Appraisal Report do not appear to reflect those presented in the Employment Land Study 2022. It is not clear why this is the case.
Land Study 2022. In addition, the SA concludes that ‘Option E’ (i.e. the option delivering the most employment) is worst performing including in terms of ‘improving air quality’, ‘reducing carbon dioxide’, ‘improving energy efficiency’, ‘reducing the need to travel and promote sustainable modes of travel’.
4.6 The SA appears to have reached this conclusion on the basis that this option would result in greater increase in private car use and commercial vehicle use than other options with less warehousing. However, this assessment is overly simplistic and fails to consider that the Council’s strategy of relying on neighbouring authorities to meet strategic warehousing needs could result in promotion of less sustainable commuting patterns and freight movements than would be the case than if those needs were met locally within close proximity to the existing and proposed population in Bedford. It also fails to recognise the strategic importance of logistics as critical infrastructure nationally, regionally and locally or the Government’s ambitions to achieve a net zero freight sector by 2050.
4.7 Option E also scores more poorly than Option D against the objective of promoting a strong, sustainable and balanced economic growth stimulating job creation across a range of sectors. It is not clear why this is the case, the SA simply suggests that low density office development with greater proportion of warehousing “uncertain whether this will be viable locally”. The market evidence above clearly demonstrates that warehousing is viable in this location.
4.8 The Development Strategy Options Paper (DSO) and SA also consider a range of strategy options as ‘reasonable alternatives’. The SA notes that for the purpose of identifying ‘reasonable alternatives’ the aim is to consider options that could meet the dwelling and employment requirement to 2040. However, it later goes onto state that the employment requirement is not considered an overriding constraint in generating options. Indeed, it is acknowledged in the DSO that most of the ‘reasonable alternatives’ identified would fail to achieve the amount of employment land contemplated in the Plan without additional sites being identified along the A421 corridor, the implications of which do not appear to have been considered as part of the assessment of strategy options. Overall, whilst we agree with and support the identification of the area around Kempston Hardwick as a location for significant growth, Cloud Wing is concerned that the approach to the distribution of other employment land in the Borough is not appropriately justified.
4.9 Cloud Wing is also concerned that the approach taken means that the opportunity presented by a larger Business Park, incorporating a mix of employment uses, on Cloud Wing’s land to the South of Bedford as part of the overall spatial strategy and distribution of employment growth, has not been appropriately considered or assessed as a ‘reasonable alternative’ as part of the Council’s Local Plan evidence base. This approach risks missing a major opportunity for economic growth on a transformative scale that is well-located to benefit from improved rail connectivity.
4.10 More generally, the Council’s approach to the assessment of and selection of ‘other employment sites’, particularly those along the A421 Corridor, is not clear or transparent. Para 5.18 of the DSO states that other potential employment locations “have been assessed according to their accessibility, visibility and proximity to strategic transport routes, and their compatibility with neighbouring uses”. However, there does not appear to be any evidence of this in the evidence provided beyond the general site assessment proforma in the appendices to the HELAA and no explanation on how judgements have been reached about particular sites.
4.11 Cloud Wing remain concerned that the Council’s proposed spatial strategy results in a ‘piecemeal’ approach to employment development elsewhere across the Borough, and an over-reliance on ‘innovation’ uses to deliver its economic needs. This approach would result in a number of individual developments
without the critical mass to generate the level of investment required to facilitate the infrastructure needed and deliver sustainable economic development. It is also unlikely that innovation uses alone would be able to generate the significant uplifts in land value that major industrial and logistics schemes generate28 and that are often needed to fund strategic infrastructure requirements (e.g. new and improved junctions on the strategic road network and link roads) and can support the delivery of other infrastructure that is required to support housing delivery on mixed-use schemes.
4.12 For example, at the Linmere development in Houghton Regis in Central Bedfordshire the delivery of large scale logistics space alongside 5,000 dwellings and other uses has provided upfront funding to support the delivery of early infrastructure for the wider scheme29. A piecemeal approach to employment development across Bedford and over-reliance on innovation uses would result in individual developments each without the critical mass and market conditions to generate the level of investment required to facilitate the infrastructure needed to support the scale of development anticipated and deliver sustainable economic development.
28 BPF (2022) Levelling up - Logic of Logistics
29 BPF (2022) Levelling up - Logic of Logistics

Comment

Representation ID: 9893

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

4. Housing Supply
4.1 Paragraph 1.3 of the Development Strategy Paper states:
“Over the plan period, in total, the Council will need to allocate land to enable a minimum of 27,100 dwellings to be delivered (20 x 1,355). Current commitments (including completions since 2020) amount to around 14,800 dwellings which means that land to accommodate in the region of at least 12,280 dwellings plus a reasonable buffer must be allocated in the new local plan.”
4.2 Paragraph 1.3 of the Development Strategy Paper states:
“Over the plan period, in total, the Council will need to allocate land to enable a minimum of 27,100 dwellings to be delivered (20 x 1,355). Current commitments (including completions since 2020) amount to around 14,800 dwellings which means that land to accommodate in the region of at least 12,280 dwellings plus a reasonable buffer must be allocated in the new local plan.”
4.3 The LPA’s 5 Year Supply of Deliverable Housing Sites 2021/22 to 2025/26 statement sets out the current position on the 5 year supply. A number of points arise:
• For the first 6 years of the plan period for the 2030 Plan there is a shortfall of 1,333 dwellings;
• The total supply in the 5 year period is 4,851 dwellings which comprises:
o 21/22 – 987 dwellings
o 22/23 – 994 dwellings
o 23/24 – 1,089 dwellings
o 24/25 – 969 dwellings
o 25/26 - 812 dwellings
• The total supply in the first 5 years of the trajectory in the 2040 plan (Appendix 1 of the Stepped Trajectory Topic Paper) is:
o 21/22 – 966 dwellings
o 22/23 – 977 dwellings
o 23/24 – 1,089 dwellings
o 24/25 – 952 dwellings
o 25/26 - 866 dwellings
• This totals 4,850. This is a shortfall of 1,995 against the standard method.
4.4 A key point is that the new allocations proposed in the 2040 Plan have made no change to delivery in the first 5 years of the plan period. This Plan is the opportunity to bring forward sites, particularly small and medium sized sites as required by paragraph 69 of the Framework or larger extension sites that can deliver early in the plan period and in full in the next 5 years. Our client’s two sites at Wootton and Biddenham can both deliver in the 5 year period.
4.5 Paragraph: 039 Reference ID: 61-039-20190315 of the PPG (What are the steps in gathering
evidence to plan for housing?) states:
“Authorities can use this evidence to:
• prepare or update their Strategic Housing Land Availability Assessment jointly with the authorities within the defined area or individually to establish realistic assumptions about the suitability, availability, and achievability (including economic viability) of land to meet the identified need for housing over the plan period, including robust evidence of deliverability for those sites identified for the first 5 years of the Plan
• prepare a viability assessment in accordance with guidance to ensure that policies are realistic and the total cost of all relevant policies is not of a scale that will make the plan undeliverable.”
4.6 Paragraph 68 of the Framework states that “specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan”. Developable is then defined as "sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.
4.7 The Executive Summary in the Viability Study states:
“Our assessment identifies that one of the six strategic sites tested (River Valley Park) is viable and deliverable with respect to the Council’s planning policy requirements (including affordable housing) at current costs and values. We note, however, it is viable only at the lower greenfield benchmark land value. The Council have identified additional infrastructure requirements to be provided in the River Valley Park strategic site, which our sensitivity testing has been shown to impact on the viability of the site. At current costs and values when the Watersports lake contribution is factored into our assessment, the site is unviable even at 0% affordable housing. The study identifies, however, that the site is viable and can accommodate the additional identified infrastructure and 30% affordable housing when growth in sales values and inflation in build costs are allowed for in the assessment.
We have also sensitivity tested lower levels of affordable housing and note that the Land East of Wixams and Gibraltar Corner sites can viably deliver 10% and 5% affordable housing when assessed at current costs and values and measured against the lower greenfield land value benchmark.
The two largest strategic sites (Little Barford and Kempston Hardwick) are identified as having challenging viability at current costs and values. However, in our experience of assessing the viability of such large schemes this is not unusual, and developers frequently rely on value growth through regeneration premiums and maturity factors to deliver them, particularly given the significant upfront infrastructure costs associated with their delivery, which can impact on cashflows.
Given the long timescales over which the strategic sites will be developed, the NPPF identifies in the definition of “Developable” sites in the Glossary at Annex 2, that it is reasonable and acceptable to factor in growth into the assessment of their viability. Our appraisals factoring in appropriate growth in sales values and inflation in build costs over the identified development periods demonstrate that all of the identified strategic schemes tested in this study are viable and therefore developable delivering 30% affordable housing.
We therefore consider that the identified strategic sites are developable and able to support the emerging LP2040 policy requirements. Further, the Council’s policies build in an appropriate level of flexibility i.e. Policy DM1 (S) (Affordable Housing) is applied subject to viability and allowing for future reviews of viability as the development progresses. This will ensure that the strategic sites can come forward and will deliver the maximum reasonable quantum of affordable housing and infrastructure contributions.”
4.8 This shows that the Plan is predicated on viability issues being addressed later in the plan period (by increased land values driven by increasing house prices) and if there are issues at that time then less (or no) affordable housing would be delivered. Figure 2.25.1 (Average house prices in Bedford Borough) show an increase from 2013 to 2021. That increase corelates with the ratio of median house price to median gross annual earnings as set out below.
SEE GRAPH IN ATTACHMENT
4.9 If that correlation remains, for the allocations to be viable house prices have to increase. As we set out under DS3 there is a significant and worsening affordability crisis in Bedford and the implications of the viability assessment is that it will worsen further in order to deliver these sites. Smaller and medium-sized sites that can viably deliver affordable homes now should have been prioritised.
4.10 To conclude, the evidence on the deliverability and developability of the sites in the trajectory does not form part of this consultation and a critical assessment of the sites must be undertaken as part of the Examination.