3.5

Object

Representation ID: 5645

Received: 07/09/2021

Respondent: Mr Phillip Yockney

I had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Support

Representation ID: 5696

Received: 07/09/2021

Respondent: Miss amber scally

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 5756

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

I had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 5794

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

I had understood that delivery had to be constant i.e., approx. the same number per year. I believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 5811

Received: 07/09/2021

Respondent: Mr Glen Moore

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).
It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.
It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.
Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 5856

Received: 08/09/2021

Respondent: Mr Norman Hoy

I had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 5880

Received: 08/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise significant concerns in relation to the potential for a stepped trajectory to be taken forward in the Local Plan 2040.
The effect of a stepped trajectory, deferring the delivery of the standard methodology until 2030, is to significantly undershoot on the delivery of annual housing need. In itself this is a significant failure, but in this instance the significant adverse impacts are compounded by a Local Plan adopted based on a low locally derived housing need future and therefore already under delivering against actual housing need.
This means that real people in real need now cannot access the housing market because of the lack of housing, affordability ratios will significantly increase and those people on the housing waiting list will also be unable to access affordable housing given that the primary source of affordable housing is from open market housing sites.
A stepped trajectory runs counter to the provisions of Policy 1S of the Local Plan 2030, a policy put in place to ensure an immediate plan review so as to meet the requirements of the standard methodology. If put in to effect, a stepped trajectory would mean that for Bedford the standard methodology will not take effect until approximately 12 years after the standard methodology was first brought in, which by any measure is wholly inappropriate and unjustified.
It cannot be said that the Council do not have the range of smaller and medium sized sites to enable a smooth rather than stepped trajectory – a significant number of the 430 call for sites submissions are capable of being brought forward without significant on or off site infrastructure. This basket of sites can be delivered without delay and do not justify a stepped trajectory.
Paragraph 3.3 of the Local Plan 2040 refers to the considerable challenges in meeting the requirements of the standard methodology. Those challenges will only increase if a stepped trajectory is put in place, since the second half of the plan period will require on an annual basis housing delivery far higher than even the standard methodology.

Support

Representation ID: 5933

Received: 08/09/2021

Respondent: Mr Tom Tagg

I support the stepped trajectory approach for the following reasons:
• It will give BBC more time to make the correct decisions on the basis of firmer information such as: the Ox-Cam Arc Spatial Strategy will be agreed; Black Cat/A428 upgrade plans will be approved; and EWR route and station locations will be decided. These are current significant unknowns and planning now will be a potential waste of time and tax-payers money, and some or all of the work will have to be repeated when these major issues become clearer. Alternatively, incorrect decisions may be made locating developments in the wrong parts of the borough – these are major decisions that will have a lasting impact on the borough and the lives of the residents forever.
• There will be time for integrated planning with Central Beds and Hunts DC.
• The impact of new HMG planning legislation and how this fits with HMG policy to “level up” across the UK will be clearer.
• There will be time to correctly carryout the traffic modelling to include employment land and correct numbers of vehicles leaving in the AM peak hour from any new settlements (current errors in the traffic models to date – as my responses to 1.23 to 1.25.
• There will be time to correctly identify the infrastructure needed to be in place to deliver the plan – this may be potentially major, e.g. widening the A421 to twin three lane.
• There will be time to embed new Environmental regulations.

Object

Representation ID: 5977

Received: 08/09/2021

Respondent: Staploe Parish Council

I had understood that delivery had to be constant ie. approx. the same number per year. I believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Support

Representation ID: 6025

Received: 08/09/2021

Respondent: Mrs Christina Farmer

I had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 6050

Received: 09/09/2021

Respondent: x Gates/Kitchiner

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6057

Received: 09/09/2021

Respondent: Mrs V Bates

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6068

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.7. The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

3.8. It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology. The Council must therefore address this shortfall in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing.

3.9. It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040.

3.10. Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West Rail section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities. There is an opportunity to accelerate development through the current allocated site at Great Barford west to ensure that there is sufficient supply of new homes into the new Local Plan period.

Object

Representation ID: 6080

Received: 09/09/2021

Respondent: Mr J Wright

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6114

Received: 09/09/2021

Respondent: Jen Giles

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 6160

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the possibility stated at paragraph 3.5 that a stepped trajectory approach may be
appropriate for this emerging local plan.
Paragraph 60 of the NPPF, states:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a
sufficient amount and variety of land can come forward where it is needed, that the needs of groups with
specific housing requirements are addressed and that land with permission is developed without unnecessary
delay.”
Whilst we acknowledge that neither the NPPF nor the PPG specify or prescribe the method by way
development plans should seek to make provision to significantly boost the supply of new homes, paragraph
68-021 of the PPG states that proposals to use a stepped trajectory must be evidenced and not seek to
unnecessarily delay meeting identified housing needs. We consider that a stepped trajectory which might
maintain the current position of 970 dwellings per year until 2030 will not deliver on the objective to
significantly boost the supply of new homes in Bedford Borough.

Support

Representation ID: 6169

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Support

Representation ID: 6215

Received: 09/09/2021

Respondent: Peter Coles

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 6245

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

The Council also consider that a stepped trajectory may be more appropriate with key infrastructure such as the Black Cat Junction improvements and the East West Rail section through the Borough due to be completed by 2030, and to take account of the time required for strategic sites or new settlements to come forward (with the ambition that new sustainable travel links will be available from day one in order to embed and promote sustainable travel choices). Whilst we recognise the ongoing infrastructure improvements within the Borough. The principle of a stepped housing trajectory is not accepted. The Council should be ensuring the housing needs are met at a consistent rate throughout the plan period rather than deferring until later in the plan period. Housing need is arising now, it is not staggered. The meeting of housing need should not be deferred. We agree that larger sites take significant lengths of time before development commences and optimum rates of housing delivery are achieved, which means that the Local Plan should allocate sufficient smaller non-strategic sized sites to complement larger sites and to ensure HLS in the early to mid-term. 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 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.

Object

Representation ID: 6260

Received: 10/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6273

Received: 10/09/2021

Respondent: Mr Bernard Cornwell

Agent: Phillips Planning Services

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6316

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 6348

Received: 10/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise significant concerns in relation to the potential for a stepped trajectory to be taken forward in the Local Plan 2040.
The effect of a stepped trajectory, deferring the delivery of the standard methodology until 2030, is to significantly undershoot on the delivery of annual housing need. In itself this is a significant failure, but in this instance the significant adverse impacts are compounded by a Local Plan adopted based on a low locally derived housing need future and therefore already under delivering against actual housing need.
This means that real people in real need now cannot access the housing market because of the lack of housing, affordability ratios will significantly increase and those people on the housing waiting list will also be unable to access affordable housing given that the primary source of affordable housing is from open market housing sites.
A stepped trajectory runs counter to the provisions of Policy 1S of the Local Plan 2030, a policy put in place to ensure an immediate plan review so as to meet the requirements of the standard methodology. If put in to effect, a stepped trajectory would mean that for Bedford the standard methodology will not take effect until approximately 12 years after the standard methodology was first brought in, which by any measure is wholly inappropriate and unjustified.
It cannot be said that the Council do not have the range of smaller and medium sized sites to enable a smooth rather than stepped trajectory – a significant number of the 430 call for sites submissions are capable of being brought forward without significant on or off site infrastructure. This basket of sites can be delivered without delay and do not justify a stepped trajectory.
Paragraph 3.3 of the Local Plan 2040 refers to the considerable challenges in meeting the requirements of the standard methodology. Those challenges will only increase if a stepped trajectory is put in place, since the second half of the plan period will require on an annual basis housing delivery far higher than even the standard methodology.

Object

Representation ID: 6382

Received: 13/09/2021

Respondent: Mr Sandy Gery

Agent: Phillips Planning Services

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 6444

Received: 13/09/2021

Respondent: Ms Donna Thompson

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Support

Representation ID: 6463

Received: 13/09/2021

Respondent: Mr Steven Kent

I had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Support

Representation ID: 6476

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Paragraph 74 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the plan period and to identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies. This should also include a buffer of a least 5%. 3. Even with a stepped trajectory, we expect the Council will need to significantly boost the number of small and medium housing site allocations in its new Local Plan to ensure a rolling five year housing supply. This is evident from the Council’s latest five year monitoring and forecast rates (Update to May 2019 report), which show much reduced delivery rates towards the latter half of the five year period: Year Estimated homes 2019/20 1343 2020/21 1198 2021/22 1007 2023/24 553 2024/25 442 4. Given the long lead in times for large scale settlements, we are of the view that further small and medium sized site allocations that do no rely on significant infrastructure delivery will be critical to the continuity of supply and the ability of the Council to meet its objectively assessed housing need. Additionally, even with allocation of strategic growth sites potentially delivering towards the latter half of the plan period (i.e. post 2030), there is still the need to allocate small and medium sites around existing settlements to provide choice and competition in the market and ensure flexibility in the housing trajectory in the event that, for instance, strategic site delivery is delayed (especially where the timing of significant infrastructure projects cannot be guaranteed).

Object

Representation ID: 6505

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth and spatial strategy options (paragraphs 3.3 to 3.5)
Firstly, we wish to commend the Council on seeking to embrace a housing figure for the plan period which directly reflects our recommendations at I&O stage. At the point of the previous consultation the Council was equivocating over a figure somewhere within a wide range of 800 to 1,305 dwellings per annum (dpa). Following our own assessment of the appropriate housing requirement for the Borough, and on review of the likely Local Housing Need figure to be used as the start point in the calculation of the Objectively Assessed Housing Need, we recommended the following:
“The indicative range upon which the Borough’s emerging housing requirement should be based is 1,153 to 1,305 dwellings per annum. Based on a 20-year plan period until 2040 and taking into account existing commitments of approximately 11,000 dwellings this results in a revised residual requirement for the plan period of between 12,000 and 15,000 dwellings by way of new allocations.”
The Council’s current proposed annual requirement is 1,275dpa (a figure which reflects the upper end of our own suggested range) which results in a residual requirement from new allocation of a minimum of 12,500 dwelling (once again in accordance with our recommendations).
Where we do have concerns is the suggestions around the potential plan trajectory, maintaining the current delivery rate of 970dpa over the remainder of the current plan period until 2030 and only then stepping up to a requirement of 1,580 dwellings beyond this point. This would represent an abdication of the Council’s duty to boost significantly the supply of housing in the face of what is a current and urgent need for at least 1,275dpa. By way of a reminder this Local Housing Need figure is based on immediate levels of natural demand (the Office of National Statistics’ 2014-based household projections) boosted appropriately by an uplift to rectify local issues in respect of affordability. The raw ONS data alone suggests that an average of 985 new households will be created annually over the period 2020 to 2030. The maintenance of delivery of 970dpa prior to 2030 would not even meet naturally occurring demand never mind seeking to rectify issues in respect of affordability. It is imperative that as a priority the new Local Plan 2040 identifies sufficient deliverable sites that could meet the requirement for the LHN-derived 6,375 homes within the first 5 years of the plan period.

Support

Representation ID: 6543

Received: 13/09/2021

Respondent: Mrs Susan Trolley

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 6565

Received: 13/09/2021

Respondent: Challenger Multi Academy Trust

Agent: Fisher German LLP

2.10 In respect of the draft Plan’s proposal to potentially utilise a stepped trajectory, referenced at 3.5 of the draft Plan, this is something which is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is partially due to the Council’s approach with regard to the previous Plan and adopting a Local Plan with a functional period up to 2030 only, despite the concerns of a number of development stakeholders. It is to us entirely inappropriate that this can be used to fetter current housing needs to later in the Plan period. This approach is particularly considered problematic in that it is anticipated that housing needs will increase through the Spatial Hierarchy, thus further compounding delivery requirements later in the Plan period. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised and in reality, it would likely damage the authority in later years by resulting in an unacceptable annual requirement.