3.5

Object

Representation ID: 6570

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

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.

Object

Representation ID: 6602

Received: 14/09/2021

Respondent: Mr Aiden 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.

Support

Representation ID: 6724

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

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: 6762

Received: 14/09/2021

Respondent: Ms S Kelly

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: 6814

Received: 15/09/2021

Respondent: Mr Damian Smith

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: 6862

Received: 13/09/2021

Respondent: Mrs Joanna Ibbett

I 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: 6993

Received: 16/09/2021

Respondent: Mr Robert 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: 7033

Received: 17/09/2021

Respondent: Mr Robert 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.

Object

Representation ID: 7052

Received: 17/09/2021

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.
Option 2a
We raise no specific objections to Option 2a. We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
Option 2b
We raise no specific objections to specific elements contained in Option 2b, relating to proposals adjoining the urban area and transport corridor.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is marginally less reliant on the rail corridor than Option 2a and as a result on the face of it is a superior option – however the introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2b were it to be advanced with a new settlement as part of the overall strategy.
Option 2c
We raise strong objections to Option 2c.
We would question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is heavily reliant new settlements. Given how poorly new settlements fair in the assessments set out in the evidence base this option cannot, by some margin, be considered to be the most appropriate option when considered against the reasonably alternatives. It is also the case that new settlements will inevitably challenge the ability to deliver the (higher) standard method in the early phases of the plan which – as we have set out elsewhere in our submissions – is vital to the success of the Local Plan Review.
Option 2d
We raise no specific objections to specific elements contained in Option 2d, relating to proposals adjoining the urban area, transport corridor south and transport corridor east.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
The introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2d were it to be advanced with a new settlement as part of the overall strategy.
Policy NE1 – Environmental Net Gain
We do not raise any significant concerns in relation to Policy NE1, recognising the provisions of the forthcoming Environment Bill. However, the policy could be enhanced by making reference to applying the DEFRA metric as a means to benchmarking the baseline position with regard to environmental quality, and as a means to assessing the contribution that biodiversity enhancements make. This will provide for a consistent approach, and provide those bringing forward housing and other developments with certainty as to the approach to be taken.
As a separate observation, as drafted Policy NE1 makes reference to enhancing or creating off site habitats “in some circumstances”. The policy should be amended to make clear that off-site environmental net gain is an appropriate solution in all circumstances and may in fact lead to the creation of a greater environmental net gain than would otherwise be achieved on site – thus furthering the objectives behind the policy.
Paragraph 8.35
As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.

Support

Representation ID: 7082

Received: 09/09/2021

Respondent: June 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.

Support

Representation ID: 7129

Received: 09/09/2021

Respondent: Stephen 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: 7154

Received: 17/09/2021

Respondent: Mr Richard Hull

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: 7162

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

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: 7179

Received: 17/09/2021

Respondent: The Palmer Family Trust

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.

Support

Representation ID: 7209

Received: 17/09/2021

Respondent: Mr Peter Knight

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: 7294

Received: 01/09/2021

Respondent: Miss Laura Jones

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: 7370

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

Lone Star have concerns regarding the potential reliance within the draft Local Plan of use of a stepped trajectory, as set out at para 3.5. The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the emerging strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.
If the Council decide that the provision of large strategic sites is an important part of site delivery in the Borough, then the changes in the National Planning Policy Framework (“NPPF”) published in July 2021, now provide a sound policy context for Local Plans to include such proposals within the context of a 30-year Vision to recognise their longer lead in times, and prolonged delivery (NPPF para 22). The delivery of larger sites, therefore, is not a sound reason for failing to meet the aspirations of those in housing need now.
The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6 – 10. The NPPF does not support the deferral of meeting the known housing requirement to beyond year 10. The PPG (68-021) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.
The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.
is simply being deferred to later in the Plan period without justification.
Lone Star Land would encourage a strategy which does not seek to delay meeting housing need through a stepped trajectory. In order to achieve the Standard Methodology (“SM”) figure, as a minimum, the strategy should allow for a greater number of small and medium sized sites to be delivered, which are capable of being brought forward within the first 10 years of the Plan period, to meet the current need, now.
Such a strategy should necessarily look to reliance on the delivery of sites at those settlements that are consistent with the locational strategy of the emerging plan (i.e. those sites which lie, inter alia, on the A421 corridor) and settlements which have been assessed and been found by the Council to be highly sustainable in their own right, i.e. the Key Service Centres, including Great Barford.
That Great Barford only appears in one of the four Option 2 scenarios, is without any sense of evidential support or justification. As aforementioned, the Settlement Hierarchy background paper concludes that it is a highly sustainable settlement with a full range of local services to meet day to day community needs, it is close to and well connected to Bedford, with frequent public transport service provision, and is able to support further growth demonstrably without causing environmental, landscape or heritage harm, through the delivery of sites such as that promoted by Lone Star Land.
August 2021 | KF | P19-0021 Page | 8
The Council are therefore invited to review the trajectory of delivery for their Reg 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.
With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy may reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.

Object

Representation ID: 7508

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

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: 7527

Received: 21/09/2021

Respondent: EF Wootton and Son

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: 7542

Received: 21/09/2021

Respondent: Bates Bros (Farms) Limited

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: 7613

Received: 01/09/2021

Respondent: Miss Nicola Tagg

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: 7660

Received: 01/09/2021

Respondent: Mr Simon Goodship

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: 7758

Received: 22/09/2021

Respondent: Mr Michael 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.

Object

Representation ID: 7786

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

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 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: 7817

Received: 03/09/2021

Respondent: Mr Emilio Meola

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: 7856

Received: 03/09/2021

Respondent: Mr Mark Ibbett

I 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.

Object

Representation ID: 7897

Received: 24/09/2021

Respondent: Home Builders Federation

The Council note in paragraph 3.5 of this section that the Council may need to apply a stepped trajectory. Whilst we appreciate that this may be the case the Council must explore all avenues to ensure that it does not seek to push back meeting housing needs until later in the plan period or at least minimises this if a step is to be utilised. Paragraph 68-021 of Planning Practice Guidance (PPG) is clear on this issue stating that using a stepped requirement must be evidenced and does not seek to unnecessarily delay meeting identified needs.
A further reason why the Council must focus on ensuring a consistent supply of homes is to ensure that this supply supports the Government’s drive to improve affordability. The Government recognise that increased supply is a factor in ensuring that affordability does not get worse and as such any delay in meeting needs will only succeed in neutering the reason for, and the benefits of, the affordability uplift applied through the standard method.

Object

Representation ID: 7962

Received: 24/09/2021

Respondent: Ms Lorraine 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: 8019

Received: 24/09/2021

Respondent: Mr Larry Gooch

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: 8124

Received: 03/09/2021

Respondent: Dr Emma Thompson

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.