Policy DS3(S) Amount and timing of housing growth

Object

Representation ID: 10109

Received: 29/07/2022

Respondent: Rainier Developments Limited - Roxton

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

A. Introduction
1. These representations are submitted by Marrons Planning on behalf of Rainier Developments and Strategic Land in response to the Regulation 19 Draft of the Bedford Draft Submission Local Plan 2040 (DSLP2040) prepared by Bedford Borough Council (BBC). There are three main issues with BBC’s approach:
I. BBC have not satisfied the Duty to Cooperate in accordance with s.33A of the Planning and Compulsory Purchase Act 2004, paragraph 24 of the NPPF and paragraph 029 of the Planning Practice Guidance on plan-making. BBC acknowledge within their Duty to Co-operate Position Statement that neighbouring authorities have not yet had sight of their draft policies and strategic allocations, notwithstanding the late stage in the plan-making process. Necessarily, if neighbouring authorities have not seen the detail underpinning the emerging plan, it must follow that they have not meaningfully engaged with it.
II. The DSLP2040 is inflexible by relying on strategic allocations which depend on uncommitted infrastructure. For example, the emerging plan includes allocations for 5,800 homes, which depend on East West Rail (EWR) stage 3, despite the Infrastructure and Projects Authority (IPA) concluding that the project now appears ‘unachievable’ (IPA annual report, 2021-2022). Other strategic allocations depend on schemes to upgrade the Strategic Road Network (SRN), all subject to funding bids and the outcome of Road Investment Strategy 3 (RIS3). In parallel there is a lack of evidence to demonstrate that these strategic sites are developable and viable. This all presents significant risks to the DSLP2040’s delivery. Non-strategic sites in sustainable locations which could otherwise help ensure a deliverable 5-year supply have been rejected without justification.
III. The ‘exceptional circumstances’ to justify a departure from the Local Housing Need (LHN) have not been demonstrated in conflict with NPPF61. Over the first ten years of the plan, BBC proposes a housing requirement 25% below the LHN (1,010dpa vs. LHN of 1,355dpa). Furthermore, the enclosed evidence demonstrates that an uplift in the LHN to 1,744dpa is justified. The critical social and economic consequences of not meeting housing needs from the outset of the plan has not been addressed in the Sustainability Appraisal (SA).
2. These three fundamental failings of the DSLP are now expanded upon below.
B. Duty to Cooperate
3. The legal requirements of the Duty to Cooperate needs to be addressed prior to submission of the plan, as set out in NPPG031 Plan-making: “The local plan examination will first assess whether a local planning authority has complied with the duty to cooperate and other legal requirements… As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with they will recommend that the local plan is not adopted and the examination will not proceed any further…”.
4. At this late stage in the plan-making process (Regulation 19 pre-submission) BBC state that neighbouring authorities have still not had sight of the plan or the strategic site allocations within it (page 5, Duty to Cooperate Position Statements, April 2022). Unresolved issues regarding unmet housing needs, the implications of the Oxford-Cambridge Arc and infrastructure concerns regarding the capacity of transport junctions and congestion are identified throughout BBC’s Duty to Cooperate Position Statements.
5. Whilst BBC sets out that meetings and discussions have taken place, nothing constructive or substantive could have occurred insofar as cooperation and engagement is concerned if these adjoining authorities do not know what is in the plan in terms of its housing requirements, spatial strategy and allocations.
C. Lack of flexibility
Reliance on strategic-scale allocations and new settlements
6. The reliance on strategic-scale sites, including new settlements and extant plan allocations to deliver planned growth is not justified. The DSLP2040 relies on strategic sites comprising 3,175 dwellings finally coming forward on extant allocations (from the 2002 and 2019 plans), two new settlements at Little Barford (4,000 dwellings) and Kempston Hardwick (4,000 dwellings) and other strategic growth on the A421 corridor (4,750 dwellings) – all post 2030.
7. The flaws with this approach are as follows:
• BBC’s own viability evidence demonstrates that the two new settlements at Little Barford (HOU19) and Kempston Hardwick (HOU14) are unviable at the present time (Bedford Local Plan 2040 – Borough Wide Viability Study, BNP Paribas Real Estate, April 2022). The entire strategy is based on speculation that the necessary infrastructure will be in place and that market conditions will have improved to sustain the viability of these schemes.
• It is unclear how strategic infrastructure requirements have been incorporated within the viability appraisal – e.g. Kempston Hardwick New Settlement depends on A421 widening, a £60M scheme where developer funding is to also be sought (refer Infrastructure Delivery Plan (IDP) (AECOM, May 2022)). Similar uncertainty exists for other strategic allocations whereby developer contributions and funding are not identified, limiting the effectiveness of the BBC’s viability evidence.
• Delivering and funding for the strategic infrastructure necessary to unlock the strategic allocations remains uncertain. Table 5.2 of the Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory (AECOM, May 2022), sets out the required infrastructure for each strategic site, for example:
EWR
 Both Kempston Hardwick (HOU14, 4,000 homes) and Little Barford (HOU19, 4,000 homes) – entirely depend on EWR stage 3. EWR is also identified as related to the delivery of East Wixhams (HOU16, 1,800 homes). However, there is no preferred alignment as of yet, no government commitment to its delivery nor confirmed funding. The IPA have recently concluded that both EWR stages 2 & 3 are rated ‘red’ where “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability re-assessed” (IPA Annual Report, 2021-22, page 54). This now calls into question the allocation of these strategic sites, contributing 5,800 homes to BBC’s land supply.
SRN – A428 Black Cat to Caxton Gibbet
 Little Barford is also dependant on this major scheme to the SRN. It is also related to the delivery of River Valley Park (HOU 11, 1,000 dwellings). A decision on the DCO is still pending, as is the government’s funding decision.
SRN – A421 Widening
 This relates to the delivery of 11,930 dwellings comprising allocations HOU3, HOU11, HOU14, HOU16, HOU17 and HOU19. BBC’s IDP identifies that this £60M scheme is dependent on the outcome of RIS3, government funding and developer funding. The outcome of the RIS3 process – whereby BBC will need to make the case for their inclusion in this national investment strategy – is uncertain at this stage, but is clearly fundamental to the delivery of DSLP2040.
 The Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory explains that the identified SRN schemes “must be recognised in the RIS [Government’s national Road Investment Strategy] to be funded and delivered. RIS is therefore key to supporting the LP2040.”
SRN – A421 / A600 Junction
 This is identified a direct requirement to unlock delivery of College Farm (HOU17, for 1,000 dwellings). This £1M scheme is also dependant on RIS3, with a combination of funding from national highways and developer funding (the extent of developer funding remaining unclear with respect to the delivery and viability of HOU17).
SRN – B530 / Manor Road / Kiln Road
 A £5M scheme required to unlock the delivery of Kempston Hardwick new settlement, again dependant on the outcome of RIS3.
SRN – Kempston Hardwick Links
 A £5 scheme dependant on funding and investment decisions by East West Rail, again critical to the delivery of Kempston Hardwick new settlement.
SRN – Little Barford Mitigation
 A £1M scheme not expected to open until 2040, all funded by the developer. It is unclear whether or how this has been factored into the viability assessment for the Little Barford allocation.
• The delivery rates and trajectories for the strategic sites remain unjustified at this stage – for example rates of 300-600dpa projected at Little Barford and Kempston Hardwick, rates of development that are unprecedented in Barford. Furthermore, in terms of the plan’s flexibility and effectiveness, it only takes a delay of one or two years (which could be likely given the various infrastructure requirements and lead-in times) to result in a shortfall in housing delivery to 2040.
• The specific capacities of the strategic allocations and new settlements have not been evidenced – for example, HOU14 Kempston Hardwick and HOU19 Little Barford cannot realistically achieve the delivery of 4,000 homes with respect to other land-use requirements, biodiversity net gain and infrastructure requirements.
• There is no evidence that the extant local plan allocations P11, P12, P13, P14 and P25 are deliverable, given a considerable track record of delay since the adoption of plans in 2002 and 2019. No evidence is included to substantiate their rolling forward and re-allocation in the DSLP2040. As can be seen at Appendix C, these sites were expected to have come forward by 2030 in the 2018 housing trajectory supporting the LP2030 but BBC has now conceded that these are not deliverable within the adopted plan period, and pushed them even further back.
• A sole reliance on strategic sites fails to reflect the invaluable role for a mix of sites in having an important contribution to the housing needs of an area and their ability to be built out relatively quickly under NPPF69, and the need for a variety of land (NPPF60).
Lack of 5-year housing land supply
8. In the early years of the plan and even against BBC’s supressed requirements of 970dpa - 1,070dpa under the stepped approach, BBC’s trajectory shows that demonstrating a 5-year housing land supply plus buffer will not be possible upon adoption of the plan (BBC estimate adoption ‘late 2023’ ).
• At 2022/23 BBC would have a supply of just 4.75 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,915 dwellings).
9. The above position is reliant on windfalls of 148dpa contributing within the 5-year period. If windfalls are removed - given the lack of justification and evidence – BBC’s position worsens.
• At 2022/23 BBC would have a supply of just 4.08 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,223 dwellings, excluding windfalls).
10. BBC’s 5-year land supply is also reliant on extant allocations and sites where ‘clear evidence’ on the deliverability is currently lacking, as set out in Appendix D.
11. Clearly, if the 5-year requirement were to reflect the minimum LHN of 1,355dpa (i.e. no stepped trajectory), or to the uplifted LHN identified in these representations (to 1,733dpa), then the shortfall in deliverable land supply worsens.
Reasonable alternatives to help boost supply
12. The SA rejects the entirely reasonable alternative (a central requirement of NPPG001 – SEA and SA) of delivering homes on non-strategic sites in otherwise sustainable locations. For example, additional growth at Key Service Centres and Rural Service Centres is rejected on the crude assumption that such locations will result in increased car dependency with associated negative consequences in terms of CO2 emissions and air quality. Spatial option 3c was dismissed on this basis and ‘village related growth’ considered the worst component of the strategy (SA paragraphs 7.10, 7.23 and 8.13). However, the Council have not properly assessed the capacity of the KSCs and RSCs to accommodate sustainable growth – there is no assessment of settlement and site options as part of the SA process.
13. It is clear that sustainable, suitable and deliverable sites are available in such locations, as can be seen from the evidence provided at Appendix E (Site 776 Land off Bedford Road, Roxton). The evidence shows that such sites are as sustainable as BBC’s preferred allocations and, crucially, are deliverable and can meet pressing local needs.

D. No exceptional circumstances to justify a departure from the LHN
Policy requirements
14. NPPF61 requires that “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” (Emphasis added).
BBC’s approach and exceptional circumstances
15. BBC proposes a stepped trajectory, whereby provision runs at 970dpa for the first 5-years of the plan (2020-2025), 1,050dpa for 2025-2030 and 1,700dpa for 2030-2040. For the first 10 years of the plan period it therefore averages 1,010dpa, 25% lower than the LHN of 1,355dpa, an overall shortfall of 3,450 dwellings 2020-2030.
16. BBC’s justification for this approach is that there will be long lead-in times to bringing forward the strategic-scale allocations and associated nationally significant infrastructure, which is unlikely to be resolved until 2030 at the earliest. It is based on the assumption that the currently unviable new settlements will be viable post-2030 and that there will be greater certainty on the delivery of infrastructure by this point too (e.g. that commitments and funding decisions will have been made regarding EWR and the outcome of whether funding bids to RIS3 were successful will also be known).
17. However, BBC has not demonstrated why these circumstances are exceptional, with no consideration of market signals nor future demographic trends as NPPF61 requires. In fact, evidence undertaken by Marrons Planning, demonstrates that market signals would lead towards an uplift to the LHN, by at least 378dpa - to 1,733dpa, as explained in the Housing Needs Assessment at Appendix A.
18. Furthermore, BBC has embarked on their strategy without testing the implications of a failure to meet the LHN. The SA simply concludes that the stepped trajectory’s implications for housing delivery will be ‘? uncertain’ (SA, Appendix 8, page 113, SA Objective 12). For such a significant issue which goes to the heart of the whole plan and could hinder achievement of sustainability objectives for economic growth (SA objective 5), providing for residents’ needs (SA objective 13) and social cohesion (SA objective 14) as well as people’s quality of life, health and well-being, this lack of evidence and assessment is a significant omission.
19. On the basis of the above it is clear that exceptional circumstances have not been demonstrated, in conflict with NPPF61.
E. Conclusions
20. These representations demonstrate fundamental failings with DSLP2040.
21. In the first instance, the requirements of the Duty to Cooperate cannot be met, and the plan, as drafted, would be unlikely to progress past the first part of the examination process.
22. In terms of matters of soundness:
I. The plan is inflexible, ineffective and in conflict with the government’s ambition to boost the supply of homes (NPPF60), relying on strategic sites and associated infrastructure, the delivery of which is all uncertain.
II. There are no exceptional circumstances to justify a 25% reduction in the LHN over the first 10 years of the plan period.
23. Taking forward the DSLP2040 could have significant economic impacts given Bedford’s location within the Oxford-Cambridge Arc with a failure to address objectively assessed needs also having severe social consequences in the context of a national housing and affordability crisis, as well as the health and well-being of Bedford’s communities.
24. Critically, none of this has been assessed in the DSLP2040’s supporting SA. Reasonable alternative strategies including non-strategic growth to otherwise sustainable locations – including sites which are deliverable, viable and available now to help boost supply and meet local needs - have been rejected.
Please note: supporting Appendices A-E which accompany these representations are attached and enclosed.

Comment

Representation ID: 10115

Received: 29/07/2022

Respondent: Mr Martin Towler

The Cpre claim this number is wrong and I would support this, the arc is dead so this plan is out of date already

Object

Representation ID: 10125

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

c) Relationship With The Proposed Requirement for a Stepped Trajectory
3.12 PPG ID: 68-021-20190722 notes that a stepped trajectory may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies or to accommodate the phasing of strategic sites. The PPG also addresses how past shortfalls should be considered when assessing housing completions against planned requirements (PPG 68-031).
3.13 For Bedford it is correct that upon commencement of the new plan period from 2020 past under-delivery or over-delivery prior to this date is reflected in the result of the calculation of the standard method and application of the affordability adjustment (ID: 68-031-20190722). This is a significant point. The Council previously argued that it was necessary to calculate any surplus/’oversupply’ against the NPPF (2012)-derived objectively assessed need of 970dpa prior to 2020, That argument has now been completely negated.
3.14 It is also relevant to note the contents of the PPG in respect of local housing need. PPG ID: 2a-010-20201216 notes that previous levels of housing delivery may be a relevant indicator in considering whether to plan for needs greater than those indicated by the result of the standard method.
3.15 The following points further demonstrate, with reference to the Local Plan 2030 and PPG ID: 68-021-20190722, that reliance on the stepped trajectory proposed by the Council is not justified in the circumstances.
3.16 Firstly, recent levels of delivery broadly accord with the outputs of the standard method, notwithstanding a small reduction in output between 2019/20 and 2020/21. This is not surprising, with the upturn in completions since 2015 largely being reflective of rectifying (in- part) early delays to achieving the growth ambitions of the area reflected in the 2008 Core Strategy/Regional Spatial Strategy and delivery of commitments first identified in earlier plans.
3.17 It is worth reiterating that in terms of recent levels of delivery and their relationship with housing need the need to address these earlier delays is reflected in the standard methodology and its measures to address worsening affordability as well as enabling sustainable commuting patterns. The earlier conclusions of the Council’s consultants, Opinion Research Services (ORS) that the 2014-based projections from which the standard method is derived are likely to overestimate future growth (due to perceived errors in the 2011 Census estimates) have been proven incorrect by the most recent 2021 Census estimates.
3.18 Projected growth in the 2014-based series has been met and exceeded to 2021, as shown in the comparison below in Figure 1 below, albeit annual rates of delivery below have been slightly below the current calculation of LHN.
[See Fig 1 in attachment]
3.19 While this does not itself indicate a need to plan for a higher level of need than indicated by the result of the standard method the trend is indicative of high levels of market demand and suggests that minimum local housing need provides a stable basis for plan-making in the area, as intended by Government. The requirement under national policy to sustain these trends is neither new, surprising or unexpected.
3.20 The difference between the 2021 Census estimate and the 2018-based subnational population projections used in the Council’s demographic analysis of utilising a stepped trajectory9 is around +9,000 persons. This is at least in-part likely to be a result of substantially higher net in-migration to the area than recorded in previous official mid-year estimates (as set out in Figure 8 of the Council’s analysis). The impact on levels of population and household growth relative to recent trends will therefore be substantially greater than indicated in the Council’s current evidence base.
3.21 Making provision for a downward step-change as indicated by the Council’s trajectory is the antithesis of securing the Government’s objective to boost supply under NPPF 60. Compared to recent trends it is likely to encourage adverse effects in terms of affordability, household formation, commuting patterns and supporting growth of the labour force locally consistent with the Council’s ambitions for economic development. Implementing a stepped trajectory as proposed by the Council is therefore inconsistent with numerous facets of national policy and guidance and its introduction must be very carefully considered in order to cause the minimum possible delay to meeting future needs.
3.22 Secondly, recent levels of completions have been achieved within the context of overall policies of significant restraint in the rural area, prior to the conclusions of the Local Plan 2030 that in principle the spatial strategy could sustainably cater for the distribution of growth to Key Service Centres and Rural Service Centres.
3.23 Thirdly, in relation to the phasing of strategic sites the PPG must be considered in the context of earlier plan-making. The Council has had many years, including the entire Local Plan 2030 process, to have identified and made strategic land allocations at earlier stages. In seeking an earlier ‘reprieve’ while still suggesting its current Local Plan met national policy objectives to boost supply the Council could be expected to accommodate a spatial strategy that would have minimal implications for supporting the long-term phasing of new strategic sites in the future. The stepped trajectory now proposed demonstrates that this is not the case. Total delivery proposed in the Council's stepped trajectory for the period 2020 to 2030 (10,100 dwellings – assuming the Council’s delivery forecasts for identified sites are robust) is only around 800 dwellings greater than the LP2030 trajectory for the same period (9,281 dwellings). This indicates little if any effective plan-led response to boosting supply to meet needs within the Plan for Submission. In now reiterating concerns regarding the phasing of strategic sites, having opted not to allocate these at earlier stages, the Council is further compounding the challenge of delivery and relying on past excuses to defer meeting needs.
3.24 Fourth – and most significantly – the Council’s conclusion is fundamentally reliant on acknowledging that the LP2030 strategy was and has been incapable of meeting expectations for a boost in supply 2020-2025. For the same five-year period the LP2030 housing trajectory anticipated delivery of around 1,120 dwellings per annum. This cannot be regarded as a significant change from the requirement to satisfy local housing need, which the Council was already aware of. In reality the Council now acknowledges that the whole strategy upon which it relied to adopt the LP2030 has in effect been deferred backwards into the plan period, hence a proposed stepped trajectory for this period of 970dpa (over 13% below the expectations from its own Plan adopted less than three years ago).
3.25 Acknowledging these past failures should provide clear justification to prioritise sites that can be delivered early in the plan period, in accordance with the PPG (ID: 68-021-20190722) rather than reinforcing reasons to delay meeting needs. This is considered further below. The Council’s proposed use of a step trajectory, particularly to the extent proposed, simply extends to gap between a failed strategy and identifying opportunities to meet needs in full (or even to ensure that the prospects for delivery secure levels of completions recorded pre- 2021)
d) Failures in Delivery of Provision Identified Within the Local Plan 2030
3.26 The delays and failures in respect of the Bedford Local Plan 2030 are most evident when considering the trajectories of the 2030 Plan and 2040 Plan for individual sites and locations for growth. It is here that we can see an acute problem with the delivery of allocated sites. In a number of instances, some of which are highlighted below, delivery on allocated sites, including a large capacity for housing identified in Bedford Town Centre, has simply been pushed back from that expected on adoption of the 2030 Plan.
3.27 For instance, the Greyfrairs allocation was expected to deliver circa 70 dwellings per annum from 2021 in the 2030 trajectory (200 in total), whilst the 2040 trajectory pushes back first delivery to 2029 and reduces build out to 50 dwellings per annum.
3.28 The same is true of the large Ford End allocation, were delivery was expected to commence in 2021 at a rate of between 68 and 117 dwellings per annum (630 in total). Again the 2040 trajectory pushes delivery back to 2029 and expects a rate of between 50 and 75 dwellings per annum (700 in total).The below table sets out some key differences;
[See Table 4 in attachment.]
The same is true of the Neighbourhood Development Plan allocations as demonstrated below (note these assumptions are without prejudice to our client’s position regarding the assessment of deliverability in each case);
[See Table 5 in attachment.]
e) Reliance Upon Supply from Unidentified Sites within the Local Plan 2040
3.29 It is further noted that there has been a jump in the number of windfall sites anticipated throughout the Plan period against the 2030 Plan period. The LP2030 housing trajectory includes a total of 958 dwellings for the period 2020-2030, whereas the Council’s Stepped Trajectory includes 148dpa from 2021/22 to 2025/26 and 135dpa thereafter (equivalent total to 2030 of 1,280). These totals include the Council’s allowance for delivery on small sites (0- 4 dwellings) not captured separately in the trajectory but are also inclusive of a figure of 90dpa windfall on sites comprising 5-24 units in the urban area as set out in Appendix 2 of the Council’s most recent Housing Land Supply Assessment.
3.30 Average windfall supply from the 5-24 units component has increased since 2016/17, which is very likely to be a function of trends related to conversion under Permitted Development Rights but not subject to any detailed assessment of whether these trends can realistically be expected to continue as part of the Council’s evidence base (and as required by NPPF2021 Para 71). This will need to be fully justified and upon further evidence, and we retain the right to explore the windfall allowance further. This is particularly important where the Plan for Submission also seeks to specifically allocate several sites of under 25 dwellings and therefore the Council must ensure no ‘double-counting’ of these sources of supply. The policy proposals within the Plan for Submission, such as Policy DM5 relating to thresholds for the provision of self-build plots from small sites, may also impact upon windfall supply.
3.31 In any event, the difference in the approach to total identified provision between the LP2030 and LP2040 trajectories is not reflective of a plan-led response to boosting supply and does not offer any support for the reasons to rely on a stepped trajectory. If past rates of windfall supply are not maintained there will be a further increase in the ‘gap’ to meeting needs in full.
f) Summary and Updated Delivery Assessment
3.32 It is clear that even after just 2 years from adoption, there are considerable issues with the strategy and allocations contained within the 2030 Plan. Notwithstanding, our continued assertion that the adopted housing requirement of 970 dwelling per annum was artificially constrained and not reflect of the full objectively assessed need for housing, we have considered the Council’s claimed housing land supply again this requirement for the next 5 plan years.
3.33 The sites assessed here and considered in the Council’s latest trajectory almost exclusively comprise existing allocation from the 2030 Plan, some of which were carried forward from the 2002 Plan.
3.34 As demonstrated within the supporting Deliverability Assessment Update (copy at Appendix 1), we have concerns that the Council will not be able to demonstrate a supply at adoption and furthermore, will be unable to demonstrate a supply at the 2nd and 3rd step of the trajectory.
3.35 Having reviewed the sites in detail we have identified common issues that are contributing to this expected shortfall over the next few years.
3.36 In particular we have identified that the Local Plan 2030 carried forward a number of Town Centre sites from the 2002 Plan and the sites have thus far failed to deliver the level of growth anticipated. It is understood that viability is a key component of the issue here, with previous viability work supporting the 2030 Plan having significantly over-estimated land values, which subsequently cannot be achieved. In allocating so many sites in the Town Centre the Local Plan 2030 also exposes known issues surrounding delivery rates, achieving an appropriate housing mix (including provision of family housing), securing affordable housing and securing provision for the housing needs of different groups
3.37 There has been a notable failure to address local priorities for matters including community, social, and green infrastructure as well as enhancing existing facilities and job opportunities/ This is because the allocation of land in Key Service Centres and Rural Service Centres was in the 2030 Plan largely deferred to Neighbourhood Development Plans.
3.38 Whilst we supported a strategy that included development in these areas, almost all of the Neighbourhood Development Plans have opted to accommodate their apportioned growth in one large allocation. Concerns relating essentially to the allocation of strategic scale growth through NDPs have been well-document as part of previous representations on behalf of our clients relating to the relevant Local Plan 2030 and NDP processes. The resultant delays to delivery and shortcomings in the ability of the NDP process to identify and secure improvements to local infrastructure, services and facilities are not unexpected. This is an inevitability where these strategic priorities have been deferred from the Local Plan-making exercise and realistically required more detailed testing than that carried out throughout the Neighbourhood Development Plan process.
3.39 The absence of sufficient flexibility in the allocation of land in the 2030 Plan further compounds this issue and ultimately results in the Council not being able to respond to circumstances, such as those set out above, whereby delivery is delayed or coming forward at a slower pace than anticipated. The Council should seek to ensure that this mistake is not made again, particularly when considering the overriding reliance on strategic scale growth proposed in the 2040 Plan.
3.40 In summary the Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the Government’s latest policy with full awareness of these issues. Pursuing a stepped trajectory, particularly in the context of the housing requirements identified by the Council, simply perpetuates these problems.

Object

Representation ID: 10127

Received: 29/07/2022

Respondent: Bletsoes

Agent: Rosconn Strategic Land

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RSL are of the opinion Policy DS3(S) is unsound as it is not consistent with the requirements of national policy.
During the examination of the Local Plan 2030, the Inspector required the Council to undertake and submit a review of the Plan for examination within three years of its adoption on the basis that the current housing requirement of 970 dwellings per annum was based on the previous housing needs methodology, and not the Standard Methodology. Therefore, the Council needs to consider the review in the context of the elevated housing requirement as set out in the Standard Methodology. This version of the Draft Plan has retained the use of a stepped trajectory to deliver homes within the plan period up to 2040, whereby it is expected that 970 dwellings per annum (dpa) will be delivered in the period up to 2024/25, rising to 1050dpa up to 2029/30 and then to 1,700dpa up to 2039/40. The Council’s justification for the use of the stepped trajectory is in order to adapt to the significant increase in the annual housing requirement (from 970 dpa in the Local Plan 2030 to 1,355dpa which is an uplift of 40%) and the need to link growth to the completion of new infrastructure.
Paragraph 68-021-20190722 of the PPG states that using a stepped requirement must be evidenced by the policy maker and must not seek to unnecessarily delay meeting identified development needs. RSL are of the opinion the approach of pushing the majority of homes to be delivered towards the last 10 years of the plan period rather than seeking to address the uplift in housing need at the earliest opportunity in the plan period will undoubtedly create a far greater burden between 2030 and 2040 on the Borough. RSL note that the annual delivery of new homes as suggested in the proposed stepped trajectory will not exceed, or even equate to, the identified minimum annual requirement calculated by the Standard Method for the Borough until beyond 2030. The Council, therefore, are at risk of unnecessarily delaying meeting the identified development needs for the Borough, contrary to NPPF para 60.
As a consequence of this, the Council are not addressing the housing affordability issue in the Borough which exist now. According to the most recent affordability ratios published in March 2022, Bedford’s affordability ratio increased by 1.27, indicating affordability has significantly worsened in the year between 2020 (8.92) and 2021 (10.19). This is higher than England’s average ratio estimate that full-time employees could typically expect to spend their annual earnings on purchasing a home (9.1). RSL consider that the proposed stepped trajectory as currently outlined significantly risks affordability in the Borough worsening unnecessarily up to 2040. As such, in RSL’s opinion, the Council need to reconsider the stepped trajectory accordingly to not delay addressing the affordability issue.
Having adopted a spatial strategy that is not consistent with national policy (as set out in RSL’s response to Policy DS2(S)) it has resulted in the need for the Council to use a stepped trajectory which has the effect of delaying the delivery of housing for the first 17 years of the plan period. In the context of a housing crisis and housing affordability worsening, RSL consider the Plan fails to positively prepare for the area’s objectively assessed needs, provide sufficient justification that the strategy is appropriate, deliverable over the plan period and consistent with national policy as set out in paragraph 35 of the NPPF. As such, RSL consider the Plan unsound.

Object

Representation ID: 10132

Received: 29/07/2022

Respondent: Roebuck Land and Planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Stepped Delivery Topic Paper
The delivery of the EWR scheme to justify rail-based growth at Little Barford is so fundamental to the Plan that it has become the main justification for the stepped trajectory. Once again, we would argue that this is based on incorrect assumptions and a reassessment is necessary to ensure that this is sound.
Leaving aside the issue of the increase in annual housing requirement as arguably this should be addressed through the allocation of sites through the Local Plan, the main reason for the stepped trajectory is the delivery of the EWR and the A421 relief road. As such it is suggested that once the relief road is in place and the Local Plan has been adopted, there is no reason to delay the delivery of much needed housing towards the back end of the plan period. We therefore suggest that from 2025/2026 the plan should seek to deliver the full housing requirement and that the stepped trajectory is no longer relevant at that time.
This would therefore mean that Policy DS3(S) ‘Amount and timing of housing growth’ would need to be amended to reflect a revised trajectory. It is proposed that for the first six years of the plan, (which relates to the delivery of the A421 relief road) a lower delivery rate to 970 dwellings per annum is applied, however once the A421 improvements are in place, the delivery rate should be evenly distributed over the remaining years of the Local Plan (i.e. 21,280 dwellings should be delivered in the remaining 14 years) this would equate to 1,520 dwellings per annum for years 2025/26 – 2039/40.
For reasons set out in our representations to the plan, it is not possible to rely upon EWR infrastructure to justify an increase in the delivery rates from 2030 onwards for Little Barford. There is no justification for the high delivery assumptions thereafter which culminate in reliance upon 600 homes per annum during the last 3 years of the plan period. There has been no assessment of market absorption in this specific location, having regard to the overlap with the Housing Market Area of St Neots within which it will sit and rely upon for wider services during its construction and post completion. St Neots is a key focus for growth within Huntingdonshire’s current local plan strategy to 2036 and the impact of delivery rates needs to be tested within this wider Housing Market Area context.

Object

Representation ID: 10158

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable site’s leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of site’s. All the brownfield site’s will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack site’s from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated site’s.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting site’s that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large site’s that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.

Object

Representation ID: 10202

Received: 29/07/2022

Respondent: Bloor Homes

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Even if the spatial strategy survives, the stepped trajectory set out in Policy DS3(S) has not been fully justified. The proposed spatial strategy relies upon the delivery of strategic scale allocation sites particularly but not exclusively between 2030-40, with insufficient contingency provided in the form of small and medium sized sites which can be brought forward without a dependency upon the delivery of major infrastructure.

The Local Plan makes insufficient provision as part of the uplift, especially between 2030-40, for increasing supply, choice and flexibility, in terms of allocating small and medium sized sites to the south of Bedford. Given the recent changes outlined above, the allocation and delivery of these type of sites becomes of greater importance.

Pararaph 1.31 Table 1 (page 10) confirms that 17 Neighbourhood Plans (NPs) have been made within the Borough and collectively include allocations for 2,381 dwellings during the 2020-2040 period. A total of 14 of the 17 NPs include allocations for residential development with allocations ranging in size from 11 units to 500 units. This table confirms that:

• four of the 14 NPs which include housing allocations are located to the north of Bedford and comprise allocations of 500 dwellings. These strategic scale allocations account for 84% of the 2,381 dwellings;

• only 2 of the 14 NPs relate to settlements which are located south of Bedford; and

• only 105 dwellings (4.4% of total NP allocations) are located to the south of Bedford

The above points highlight that there is a distinctive geographical imbalance which would result in a lack of small and medium sized sites to the south of Bedford allocated via NPs. The reliance upon NP allocations is not sufficient to ensure adequate supply, choice and flexibility.

Object

Representation ID: 10207

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and Timing of Housing Growth (DS3(S))
2.16 The plan covers a 20-year period from 2020-2040 and the spatial strategy deployed in this case sees development and delivery of much needed residential units delayed until the latter half of the plan period to facilitate the lengthy preparation, consultation, submission and consideration of planning applications and the delivery of infrastructure to support existing and future residents. Draft Policy DS3(3) sets out the delivery of housing throughout this period, identifying 9,700 units to be delivered in the first 10-year period and 17,000 to be delivered in the second 10-year period. This is a wholly unrealistic breakdown and places extreme pressure on the second half of the plan. On an annual basis the final ten years of the plan expects a rate of delivery that is nearly twice the previous ten years. Moreover, this has never been achieved in Bedford borough, historically.
2.17 As context, the Housing delivery test identified that in the past three years, Bedford has delivered 964, 1255, 1371, 1371, 1026, and 1203 dwellings per annum in the past 6 years respectively. Significantly below the expectation of 1,700 per annum per year over 10 years. There is a very strong likelihood that the delivery in the second half of the period will delay and reduce leaving a potential huge undersupply of homes.
2.18 Whilst the Council can demonstrate a 5-year housing land supply at this time, this stepped approach that sees housing unevenly distributed throughout the plan period may quickly lead to an under supply. The need for this plan to identify and allocate additional small and medium sites to deliver early homes within the plan period is essential to prevent later delays.
2.19 The STPP trajectory provides an overoptimistic estimation for the delivery of HOU14, HOU16 and Little Barford in particular. To consider that these are reliant on rail and road infrastructure delivery including East West Rail and the infamous A1 ‘Black cat’ roundabout works suggest that first completions are expected in 2030 is simply not realistic. That in year 1, each of those sites are proposed to deliver a minimum of 100 units in the first year is also unrealistic, even if they start on 1st April 2030. To suggest that they might achieve completions of 200 plus from year 2 reaching a staggering 600 units per annum in 2037 at Little Barford is without credibility. Wixams has only delivered around 180 per annum on average over its entire period of delivery.
2.20 It is worth noting that there are three major sites that are relying on the infrastructure being in place for completions to start on site in 2030, therefore it only takes one of those sites to fall-behind and the trajectory is quickly undermined. Although spreading the risk might be considered a benefit on one hand it also increases the risk of partial failure as there are three chances of that happening.
Reliance on outside bodies to deliver vital infrastructure
2.21 The Stepped Trajectory Topic Paper (April 2022) that supports this plan has sought to justify the approach applied to housing delivery in the draft Local Plan. This document notes that “development at the scale required by the Standard Method requires investment at a commensurate scale to unlock growth”. Whilst it is acknowledged that the Standard Method identifies high demand for housing and a comprehensive approach in response to this is required, it is considered that the provision of strategic greenfield development and two new settlements exacerbates this need for investment. Furthermore, if the logic is that large new settlements is an essential long-term solution to the high requirement, then pragmatically the delivery of those settlements should be phased over multiple Local Plans and not compressed into one. History shows that new settlements take more than 20 years to evolve and then complete and this significantly longer than the present plan timetable.
2.22 The STTP at para 2.2 identifies “in particular” both East West Rail and strategic highway improvements need to be delivered to successfully meet the trajectory proposed. These two constraints are extremely difficult to predict and rely on delivery outside of the control of Bedford Borough Council and the land promoters of the sites that rely on their delivery. To base 88% of all allocations in this plan on the delivery of further rail, road and other strategic investment, there needs to be an acknowledgement of the past and a trajectory that builds in flexibility and has a cautious approach to delivery.
Recognising comparable cases (Wixams)
2.23 One of the many rail infrastructure requirements is the new station at Wixams, apparently proposed to be operational by 2024. Assuming this is a correct estimation, and this will no doubt be tested at EiP, one only has to look at how the estimation for this being delivered have over time been delayed; from being an essential requirement and justification for the original designation of the Wixams new settlement, the station has become an afterthought, and will be delivered significantly later than expected. (see Wixams a pertinent case study overleaf – Figure 2).
2.24 This is the credibility of evidence that the Council needs to reflect upon as they build their trajectory and their basis for identifying strategic sites. Knowledge of the past flawed predictions should be taken as a warning to avoid future failure. Wixams is a case that demonstrates the difficulty of making predications on the delivery of key infrastructure that rely on outside control.
The STPP trajectory is flawed
2.25 In short, the trajectory lacks realism, both in terms of the start date for completions and the annual delivery and is therefore highly risky. Reliance on infrastructure provision that is itself reliant on outside bodies undermines the soundness of the trajectory. The STPP lacks realism and there is no recognition to the experiences of the past, such as Wixams, and failing to have regard to such an important understanding of the issues that are faced undermines the credibility and soundness of this plan.
A phased approach to delivery
3.9 As stated above, the council has sought to protect the settlements in the rural area where an existing NP exists. These NPs cover the period to 2030, therefore there is an opportunity to identify land in these communities post 2030. This can either be through a NP review or and for greater certainty we advocate that specific allocations are made in this plan as Post-2030 allocations. This is a phased approach that it is not uncommon, for example Rochford District Council in Essex applied a two phased approach with a policy that allowed the post-2021 sites. For flexibility these could also be brought forward early under certain triggers such as a lack of a five-year land supply.
3.10 The reason why this would work in Bedford Borough is that it would protect the delivery of the NPs and give time for the forward infrastructure delivery of other key strategic sites to make progress and come forward. These Post-2030 sites can then be identified for inclusion in any future LP or NP or be part of a process of delivering dwellings post-2030 alongside other strategic sites.
3.11 It should be noted also that the requirement for 2020-2040 is to deliver an annual 1355 dwellings per annum over the 20 year period (based on 27,100 homes in the period 2020-2040). This requirement begins at 2020 and is higher than the requirement set out in the adopted plan for the same year which is 970 per annum (based on 14,550 homes in the period 2015-30). This demonstrates that in the early years of this plan there is a significant uplift required (385 per annum) before the strategic sites contribute and the best location for this is in the Rural Areas. This should be read alongside the evidence that in 2020 the Housing Delivery Test demonstrated that the deliver was between 1026 and 1203 dwellings in 2020 and therefore the plan in 2020 is already underdelivering against a requirement of 1355 per annum.
3.12 The period 2030-2040 in this plan already looks like a daunting challenge and that period does not have any small to medium sites proposed and an opportunity is being missed to deliver sites that are capable of early releases of housing. This approach will allow a greater number and diversity of sites releasing housing across all of the Borough with all capable of contributing to land supply without the issues of an over concentration in one place.
3.13 If this site is not considered an acceptable site for the first ten years of this plan, as we believe it should be we would ask that it is considered as an inclusion in a phased strategy post 2030.

Object

Representation ID: 10217

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable sites leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of sites. All the brownfield sites will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack sites from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated sites.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting sites that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large sites that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.

Object

Representation ID: 10223

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS3(S) Amount and timing of housing growth
Amount of Housing
2.10 Policy DS3(S) outlines the Council’s preferred approach to the delivery of housing, including the housing requirement and the temporal delivery of housing over the Plan period. This includes a ‘stepped trajectory’, with the housing requirement to increase throughout the Plan period.
2.11 The Plan utilises the baseline Local Housing Need (LHN) as the housing requirement, equating to 27,100 dwellings over the Plan period. The PPG is clear that when establishing a housing requirement “the standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area… Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” [our emphasis] (Paragraph: 010 Reference ID: 2a-010-20201216). Examples of scenarios which may justify an increase of housing requirement include growth strategies, the delivery of strategic infrastructure improvements or the requirement of an authority to take on unmet need from a neighbouring authority.
2.12 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing requirement from LHN are necessary should be undertaken prior to and independently of any consideration of the ability of an area to meet that need.
2.13 The Plan discusses the housing requirement at Paragraphs 4.7 and 4.8 of the reasoned justification, albeit there is no discussion as to whether a higher housing requirement would be justified. The reasoned justification seems to challenge, informally, the LHN requirement. The Plan asserts that population would need to increase by 50,000 people with in-migration of more than 22,000 a year above existing trends to populate homes within Bedford at the standard method rate of 1,355 dwellings per year. However, it is significant to note, and acknowledged within the Plan, that Bedford Borough falls within the Oxford to Cambridge Arc. Whilst there is a lack of clarity on the onwards direction of the top-down vision for the Arc, accelerated growth is likely to occur irrespective, led through economic demands which will drive an above historic trend rate of growth and migration. Furthermore, the Plan’s assumptions do not reflect a higher level of natural household formation rate, which may currently be suppressed due to a lack of housing or house prices more generally. Looking at historic rates of delivery could therefore become a self-fulfilling prophecy in that historic suppressed growth and/or suppressed household formation rates could be used to feed into justification for any subsequent strategies and serve to further suppress latent growth.
2.14 The LP2040 is not consistent with national policy because it does not plan for sufficient housing to meet future needs and does not proactively plan for any uplift as a result of the Arc Framework. It remains our view that a higher housing figure beyond the Local Housing Need Figure (which is intended to be a minimum figure within the PPG) should be planned for within the LP2040 in order to ensure a sound Plan.
2.15 Notwithstanding concerns relating to the delivery of the quantum of the housing proposed as discussed later within these representations, it is further noted that the Council have provided only a 5% buffer to ensure delivery. Given the reliance on difficult to deliver strategic sites which are highly likely to be delayed, as discussed within these representations, the Council at a very minimum should be seeking to provide a 10% buffer to ensure delivery, by ensuring choice and competition in the market. As set out below, the Council’s current approach monopolises housing land within Bedford to a select few landowners, which allows them to control price and delivery rates in a manner which suits them, not necessarily which delivers the quantum of housing Bedford needs.
Timing of housing growth
2.16 The stepped trajectory is proposed as follows:
• 5 years 970 dpa = 4,850 dwellings during the period 20/21-24/25
• 5 years 1,050 dpa = 5,250 dwellings during the period 25/26-29/30
• 10 years 1,700 dpa = 17,000 dwellings during the period 30/31-39/40
• 20 years average = 1,355 dwellings during period 20/21-39/40
2.17 The stepped trajectory as proposed results in the delivery of 4,850 dwellings in the first 5 years (970 per annum), 5,250 in the next 5 years (1,050 per annum) equating to 10,100 dwellings in the first 10 years. This then dramatically steps up to 1,700 dwellings per annum over the final 10 years equating to 17,000 dwellings. This is an almost 70% increase from the requirement in the first 10 years of the Plan period to the requirement for the latter 10 years. To deliver this quantum of housing, the Council is relying on undeliverable levels of growth on the two strategic new settlement allocations (Kempston Hardwick and Little Barford) as discussed below.
2.18 Paragraph 4.27 of the emerging Plan advises that there is limited opportunity to bring forward additional sites in the early years of the Plan period due to the requirements for the delivery of strategic sites and the inter reliance on new development and the completion of major infrastructure projects which is why the stepped trajectory is required with significant growth pushed back to the latter part of the Plan period.
2.19 The approach oversimplifies matters and fails to recognise the latent capacity within the wider Plan area for existing sustainable settlements to deliver growth through smaller sustainable sites; which collectively could deliver a significant quantum of supply (such as land at Kennel Hill, Sharnbrook). Crucially, this supply can be front loaded in the Plan period, as sites within the smaller sustainable settlements are generally ‘shovel ready’, essentially meaning following allocation housebuilders are able to start quickly and deliver quickly. In addition to this, the delivery of such sites ensures the Council’s overall housing portfolio is varied, appealing to both a wide range of housebuilders and housing markets, thus ensuring the greatest choice and competition in the market, which ultimately drives delivery whilst protecting the continued over inflation of house prices. This approach also helps SME housebuilders to operate in the area.
2.20 In relation to Sharnbrook in particular, it is noted that the Sharnbrook Neighbourhood Plan allocates a strategic allocation isolated from the settlement of Sharnbrook, east of both Sharnbrook Coffle End (a separate Small Settlement in the extant Local Plan) and the Midlands Main Line. This development, once complete, will in essence be a new small settlement. In this context, whilst the Neighbourhood Plan may have met its requirements in respect of the 500 dwellings allocated by the adopted Local Plan, there are no allocations within the settlement of Sharnbrook itself and there remains capacity for Sharnbrook itself to absorb growth, both within the initial years of the Plan period to assist with demonstrating a five-year housing land supply, but also up to 2040.
2.21 The AECOM Report prepared by the Neighbourhood Plan confirms that the allocated site is isolated from the main settlement numerous times, as follows:
“Although the site may appear to be adjacent to the small settlement at Coffle End, it is physically separated from it by an operational railway. The site is adjacent to some isolated small residential sites and is overall outside and not connected to the existing built up area”
“The site is outside of and removed from the existing settlement boundary of Sharnbrook. It is approximately 1.5km from the existing village of Sharnbrook, but adjacent to the small settlement of Sharnbrook Coffle End, separate by a railway line” “The site would be adjacent to Sharnbrook Coffle End and would significantly change the size of the settlement and extend Sharnbrook Coffle End to the A6 to the east.”
[our emphasis].
2.22 This unacceptability of this approach is demonstrated an appeal in Bedford, reference (APP/K0235/W/16/3161915: Land Off Station Road, Turvey). In this appeal, the Inspector states “the appeal site would adjoin Turvey Station End and not Turvey. Both settlements are separated by open countryside. I acknowledge the public footpaths through the countryside and the footpath along Bedford Road which connect them. However, these routes are not short enough to lead me to any different conclusion other than Turvey Station End is a separate settlement to Turvey”. This is the exact same position as Sharnbrook and Sharnbrook Coffle End and as such Sharnbrook, a designated Key Service Centre is yet to receive any positive allocations and thus capacity clearly exists for positive allocations as part of this Local Plan or future iterations of the Neighbourhood Plan.
2.23 A particularly concerning element of the Neighbourhood Plan proposal is moving the primary school from Sharnbrook itself, where most people live, to the new settlement which will be significantly smaller. This will inevitably encourage car journeys as for some in Sharnbrook the school will now be a significant distance away. Moreover, the key pedestrian connection, being the most direct route between the new settlement and the village, is also of concern. The footpath north of Templars Way, particularly when crossing the bridge over the railway, is very narrow. This will likely preclude some road users, such as those in wheelchairs or with buggies and prams. Whilst some areas of narrow pavement are expected, this is an extended length during which users would be very close to passing vehicles for an extended period. This footpath, particularly when crossing the bridge over the railway line, is likely to be considered as hazardous and thus is likely to be avoided. Figure 2 below demonstrates the issue, showing the narrowness of the path adjacent to a large vehicle. The Neighbourhood Plan proposed the intensification of use of this footpath for young children which is a particular concern.
SEE ATTACHMENT FOR PHOTO

2.24 Such a route will be a significant concern for many, but particularly parents who would likely need to hold tightly young children from behind or in front, given there appears to be insufficient space for two users to walk side by side, without one being forced against the wall/shrubs or be at risk from traffic. Whilst the path alongside Mill Road is better, being an underpass rather than a bridge and with a larger footpath, this route for many future residents will be a major detour, adding further to the distances one would need to travel into Sharnbrook from the new site and further increasing the use of the private car. Furthermore, it is not clear whether the education authority would actually support a new school in such a location.
2.25 It also remains unclear as to the timings of the delivery of new infrastructure, particularly the new roundabout on the A6 which is required to facilitate the development and as such it is not clear when development will commence, notwithstanding the other works necessary to facilitate the strategic scale of development of up to 500 dwellings. Whilst an outline application is submitted, it does not appear to be close to a decision. There will be the need for further work at reserved matters stage, discharge of conditions and the completion of groundworks and other preparatory measures necessary prior to the delivery of the first units. Despite this, the trajectory provided in support of the Plan considers the site will deliver 35 units in 2023/24. Cleary this is highly optimistic and likely non-deliverable. We consider it unlikely, given the requirements for significant infrastructure, that any housing will be developed in the first five years of the Plan period, reducing the supply by 130 dwellings. Given the likely need for more housing in Bedford in both the short term and Sharnbrook across the extended period up to 2040, additional sites can be allocated within the settlement to cover any shortfalls. Whilst the route between the site and the new school is not ideal for the reasons discussed above, the land at Kennel Hill is spatially optimally located to utilise both the services and facilities in Sharnbrook and the new settlement.
2.26 Sites such as Kennel Hill will likely be needed to ensure the Council is able to demonstrate a 5 year housing land supply on adoption of the Local Plan. This approach would further ensure the provision of a satisfactory buffer to provide contingency should the strategic allocations/new settlements fail to deliver, or deliver as anticipated, which we consider on the basis of evidence and our experience elsewhere is likely to be the case.
2.27 It is considered that the timing of delivery from the new settlements proposed in the Local Plan 2040 is overly ambitious and fails to reflect past delivery rates and evidence associated with bringing forward similar sites. The Wixams is a prime example. The site was first identified as a location for new housing in the late 1990s through the Bedfoprdshire Structure Plan adopted in 1997, and the Elstow New Settlement: Planning and Development Brief, adopted in September 1999. The role of the latter was to provide the framework for the submission of both the outline and reserved matters planning applications for the timely delivery of the settlement. The outline planning application for the core site was submitted in November 1999. In September 2005 the Council, in consultation with the land promoters, published and adopted The Wixams Strategic Design Guide SPD, to further guide and expedite delivery of the site. At this stage, it was anticipated that the entire development would be delivered within 15 years; this would have meant that the site would have been close to being fully built out in 2022.
2.28 However, despite this and the intervening 17-year period, the most recent monitoring report, confirms that only the initial phases have been completed in full with significant development still to be brought forward, despite construction commencing as far back as 2007 (15 years ago). In the case of the Wixams, it took over 9 from the submission of the outline planning application for the first delivery of housing, despite explicit policy support. Since then delivery has still been far slower than expected.
2.29 The Wixam’s highlights the complexity associated with the delivery of new settlements. Whilst the continued delivery of the site is of course promising, the difficulty in reaching this stage, on a site within Bedford Borough, should act as a severe warning as to the obvious pitfalls associated with strategic delivery of new settlements and should be factored into the Plan’s strategy and its over reliance on new settlements delivering the whole of the LHN moving forward.
2.30 Despite the significant delays associated with the delivery at Wixams and other strategic sites within Bedford, and also evidenced through other Local Plans which have acknowledged failure due over reliance on strategic sites (Charnwood, Rushcliffe, West Northamptonshire, etc), the Council have seemingly wed themselves to a strategy which once again, places an over reliance of strategic development, including new settlements. This approach is not justified and therefore not sound.
2.31 Start to Finish (Nathanial Lichfields) reinforces the examples above and sets out that applications for schemes over 500 dwellings are unlikely to make a contribution in the first five years. This is primarily due to the complex planning issues related to both the principle of development and the detail of implementation. Where applications have been determined more quickly than the average, this is as a result of matters being substantially addressed prior to submission which, when combined with the determination period, still adds up to the same amount of time; as the report states “there is rarely a way to short-circuit planning”.
2.32 The NLP report goes on to state:
“Planned housing trajectories should be realistic, accounting and responding to lapse rates, lead-in times and sensible build rates. This is likely to mean allocating more sites rather than less, with a good mix of types and sizes, and then being realistic about how fast they will deliver so that supply is maintained throughout the plan period. Because no one site is the same – and with significant variations from the average in terms of lead-in time and build rates – a sensible approach to evidence and justification is required.”
2.33 Whilst the site promoter may point to more optimistic timescales, a far more cautious and evidenced approach is required, with smaller and more deliverable sites allocated to deliver immediately, in order to ensure a sound Plan.
2.34 In relation to the proposed Kempston Hardwick New Settlement (Policy HOU14), it is noted that the site has no current planning status according to the Council’s online mapping. Land Registry details confirm that the site is in multiple ownership. It is not clear to what extent the landowners are in agreement as to the delivery of the site or whether there is agreement between all parties to bring the site forward. As set out above and demonstrated through the complex history associated with the Wixams, strategic scale development is difficult to deliver and takes a significant amount of time. These difficulties are compounded when the development covers multiple land ownerships.
2.35 The Little Barford proposed allocation (Policy HOU19) appears to be within a single land ownership, but will still require significant time to deliver. The site is attached to St Neots, a town within neighbouring Huntingdonshire District. It is not clear whether Huntingdonshire have commented or agreed to this proposal. Clearly by locating development here, residents are most likely to work and spend in St Neots, not within Bedford. This therefore limits the benefits provided by this housing, without any compelling justification. Bedford’s LHN should be met and development located where the need is. There is no compelling justification for the approach adopted by the Council and this is a significant concern. Not only is the delivery of the new settlements not sound, the overall approach of directing almost all of Borough’s housing need to new settlements is also unjustified and fails to reflect the housing needs of the Borough as a whole. The proposed approach to the distribution of development fails to recognise the role smaller settlements, including the Key and Rural Service Centres, play. The delivery of housing to new settlements only fails to help young people remain in the settlements where they currently live, forcing younger people and families out of villages and contributing to a lack of social diversity within existing settlements. It also fails to support the vitality and viability of existing businesses and services in rural settlements, potentially risking their ongoing operation. The approach also fails deliver a variety of housing to the housing market, preventing choice and competition as advocated in the NPPF and in the Letwin Review.
2.36 In relation to the new settlements, the Council assumes delivery on these sites will be at times 1,200 dwellings per annum collectively, equating to annual delivery of 600 dwellings per annum per site. This is highly ambitious. Nationally sites of over 2,000 dwellings only deliver on average 160 dwellings per annum. The Council’s trajectory however sets out an annual delivery rate average of 380 dwellings per annum from commencement of delivery of units in 2030/31 up to 2039/40 - in excess of double the national average for similar sites over 2,000 units. It is considered highly unlikely these anticipated rates of development will occur, particularly during the Plan period. The peak delivery of 600 units per site from 2037/38 is also considered highly ambitious and not reflected in delivery rates of other similar sites nationally, let alone within Bedford.
2.37 To ensure a sound Plan allocating suitable shovel ready sites in sustainable settlements such as Sharnbrook to deliver in the early part of the Plan period will lessen the reliance on complex sites to deliver in the latter stages of the Plan (including the NDP allocation) bringing delivery targets down to more reasonable and deliverable levels throughout the Plan period. This revised approach would enable the Council will deliver more homes in the short term, securing jobs and helping to slow the inflation on house prices. There will be further social benefits through the delivery of affordable housing at a time when there is an acute need. It will help maintain the viability and vitality of existing settlements and ensure choice and competition in the market for housing assisting delivery and market absorption. It will also ensure the Council can maintain a five-year housing land supply; which currently looks to be marginal even on adoption, if it can be demonstrated at all. This approach is a fundamental risk as the Plan cannot be found sound if there is no five-year housing land supply at adoption and will weaken the plans effectiveness if Paragraph 11 is regularly engaged. Allocating sufficient sites to ensure a robust five-year housing land supply at adoption and throughout the Plan is therefore considered to be a fundamentally benefit as the Plan cannot be adopted or reasonably function without it.

Object

Representation ID: 10225

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and Timing of Housing Growth (DS3(S))
2.16 The plan covers a 20-year period from 2020-2040 and the spatial strategy deployed in this case sees development and delivery of much needed residential units delayed until the latter half of the plan period to facilitate the lengthy preparation, consultation, submission and consideration of planning applications and the delivery of infrastructure to support existing and future residents. Draft Policy DS3(3) sets out the delivery of housing throughout this period, identifying 9,700 units to be delivered in the first 10-year period and 17,000 to be delivered in the second 10-year period. This is a wholly unrealistic breakdown and places extreme pressure on the second half of the plan. On an annual basis the final ten years of the plan expects a rate of delivery that is nearly twice the previous ten years. Moreover, this has never been achieved in Bedford borough, historically.
2.17 As context, the Housing delivery test identified that in the past three years, Bedford has delivered 964, 1255, 1371, 1371, 1026, and 1203 dwellings per annum in the past 6 years respectively. Significantly below the expectation of 1,700 per annum per year over 10 years. There is a very strong likelihood that the delivery in the second half of the period will delay and reduce leaving a potential huge undersupply of homes.
2.18 Whilst the Council can demonstrate a 5-year housing land supply at this time, this stepped approach that sees housing unevenly distributed throughout the plan period may quickly lead to an under supply. The need for this plan to identify and allocate additional small and medium sites to deliver early homes within the plan period is essential to prevent later delays.
2.19 The STPP trajectory provides an overoptimistic estimation for the delivery of HOU14, HOU16 and Little Barford in particular. To consider that these are reliant on rail and road infrastructure delivery including East West Rail and the infamous A1 ‘Black cat’ roundabout works suggest that first completions are expected in 2030 is simply not realistic. That in year 1, each of those sites are proposed to deliver a minimum of 100 units in the first year is also unrealistic, even if they start on 1st April 2030. To suggest that they might achieve completions of 200 plus from year 2 reaching a staggering 600 units per annum in 2037 at Little Barford is without credibility. Wixams has only delivered around 180 per annum on average over its entire period of delivery.
2.20 It is worth noting that there are three major sites that are relying on the infrastructure being in place for completions to start on site in 2030, therefore it only takes one of those sites to fall-behind and the trajectory is quickly undermined. Although spreading the risk might be considered a benefit on one hand it also increases the risk of partial failure as there are three chances of that happening.
Reliance on outside bodies to deliver vital infrastructure
2.21 The Stepped Trajectory Topic Paper (April 2022) that supports this plan has sought to justify the approach applied to housing delivery in the draft Local Plan. This document notes that “development at the scale required by the Standard Method requires investment at a commensurate scale to unlock growth”. Whilst it is acknowledged that the Standard Method identifies high demand for housing and a comprehensive approach in response to this is required, it is considered that the provision of strategic greenfield development and two new settlements exacerbates this need for investment. Furthermore, if the logic is that large new settlements is an essential long-term solution to the high requirement, then pragmatically the delivery of those settlements should be phased over multiple Local Plans and not compressed into one. History shows that new settlements take more than 20 years to evolve and then complete and this significantly longer than the present plan timetable.
2.22 The STTP at para 2.2 identifies “in particular” both East West Rail and strategic highway improvements need to be delivered to successfully meet the trajectory proposed. These two constraints are extremely difficult to predict and rely on delivery outside of the control of Bedford Borough Council and the land promoters of the sites that rely on their delivery. To base 88% of all allocations in this plan on the delivery further rail, road and other strategic investment, there needs to be an acknowledgement of the past and a trajectory that builds in flexibility and has a cautious approach to delivery.
Recognising comparable cases (Wixams)
2.23 One of the many rail infrastructure requirements is the new station at Wixams, apparently proposed to be operational by 2024. Assuming this is a correct estimation, and this will no doubt be tested at EiP, one only has to look at how the estimation for this being delivered have over time been delayed; from being an essential requirement and justification for the original designation of the Wixams new settlement, the station has become an afterthought, and will be delivered significantly later than expected. (see Wixams a pertinent case study overleaf – Figure 2).
[See attachment]
2.24 This is the credibility of evidence that the Council needs to reflect upon as they build their trajectory and their basis for identifying strategic sites. Knowledge of the past flawed predictions should be taken as a warning to avoid future failure. Wixams is a case that demonstrates the difficulty of making predications on the delivery of key infrastructure that rely on outside control.
The STPP trajectory is flawed
2.25 In short, the trajectory lacks realism, both in terms of the start date for completions and the annual delivery and is therefore highly risky. Reliance on infrastructure provision that is itself reliant on outside bodies undermines the soundness of the trajectory. The STPP lacks realism and there is no recognition to the experiences of the past, such as Wixams, and failing to have regard to such an important understanding of the issues that are faced undermines the credibility and soundness of this plan.

Object

Representation ID: 10230

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to policy DS3(S) stepped trajectory in so far as it relates to 2030 onwards and the reliance it places on delivery from Little Barford. The Delivery rates anticipated in the Stepped Trajectory Topic Paper are unrealistic and not achievable, irrespective of the uncertainty over the delivery of the EWR.
Please see attached representations…specifically paragraph 2.6, section 3 paragraphs 3.1-3.28, paragraph 5.6 bullet 4, section 6, Appendices A, B, C.

Object

Representation ID: 10236

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable site’s leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of site’s. All the brownfield site’s will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack site’s from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated sites.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting sites that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large sites that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.

Object

Representation ID: 10242

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable site’s leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of site’s. All the brownfield site’s will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack site’s from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated site’s.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting site’s that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large site’s that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.

Object

Representation ID: 10255

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and timing of Housing Growth (DS3(S))
The flawed approach to the identification of suitable site’s leads to a policy that delivers almost the entire requirement of this plan into the last ten years at an annual rate which is unrealistic. The rate for the last ten years is almost double that of the first five years, on an annual delivery basis.
The most recent evidence (Housing delivery test 2021) in Bedford suggests the highest rate historically is 1371 dwellings per annum. If 1,400 is achieved every year for 10 years this leaves a deficit of 3,000 dwellings that cannot be made up from any other sources of site’s. All the brownfield site’s will have been built out and there is an embargo in the rural areas in that 10 year period.
Given the lack site’s from which dwellings are being delivered, this places huge pressure on the timing of infrastructure and the delivery of each of the allocated sites.
There is no flexibility on the policy to deal with any delays. Not only is this indicative of the problem of selecting sites that have a longer than average lead-in time, it places pressure on the plan to succeed immediately given the lead-in time for the large sites that must deliver their first units in 2030, only 7 years after the likely adoption of this plan.
The plan does not take into account the significant delays that exist in preparing infrastructure for development and the process of getting new settlements into a position when they can maximize their output.
The Wixams case study is a case that the Council need to analyse and reflect upon. The plan system is based on a manage and monitor protocol and therefore reflecting on the past is an important approach.
In short, the Wixams project took from 1997, when it was first adopted to 2006 to achieve a planning permission. The first completion was in 2009, meaning that it took 12 years from adoption to the first completion. The new settlements in this plan, if adopted in 2023, would not see a completion until 2035.
The Wixams was built out by multiple developers and yet the initial phases of development have failed to deliver the number of dwellings anticipated. As of 2016 of the original first phase of 2,250 homes only 1,259 had been completed, the equivalent to 178 dwellings per annum over 7 years.
Based on the Wixams example the likelihood of an undersupply of homes across two new settlements is seriously likely to occur as it did with Wixams.

Object

Representation ID: 10349

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy. The approach is not legally compliant in respect of the Sustainability Appraisal and Duty to Cooperate processes and fails all four soundness tests.

Bedfordia has engaged at all previous consultation stages undertaken as part of plan-making for the Local Plan 2040. These representations should be read alongside the detailed Regulation 18 representations (Representation ID: 7450) submitted previously. Our client’s land has been registered under Site ID 832 (Land at Station Road, Oakley) and is considered capable of accommodating around 210 dwellings additional to those allocated within the ‘made’ Oakley Neighbourhood Plan.

These representations should be read alongside the Site-Specific Statement – Land at Station Road, Oakley and Spatial Strategy and Legal Compliance Representation Report, both of which are appended.

We consider that in order to achieve the aims of the next Local Plan 2040, higher rates of village-related growth, such as that at Oakley, must be supported from the beginning of the 2020–2040 plan period.

The Council's proposal to use a stepped trajectory is in response to earlier mistakes in estimating the deliverability and developability of sites within the adopted development plan as well as to general concerns about the suggested spatial strategy and reliance on large strategic areas for expansion.

The suggested technique is a mathematical ruse to maintain the yearly requirement in the approved Local Plan 2030 for the sake of allegedly showing a Five-Year Supply at approval (at least according to the Council's figures). It does not render a fundamentally flawed strategy "sound." The stepped trajectory is an admission by the Council that its current planned strategy (and identified provision) cannot increase housing supply. It also does nothing to allay legitimate concerns that obstacles to the deliverability and developability of sites identified after 2030 will significantly hinder meeting the housing requirement over the plan period.

We assert that the Council's ability to demonstrate a sufficient supply of housing over several 5-year intervals in accordance with NPPF2021 paragraphs 73 (large-scale sites) and 74 (housing land supply) is fundamentally compromised, without prejudice to our client's opportunity to submit a further in-depth review of the Council's assumptions for deliverability and developability of sites as part of the information it intends to rely upon at Examination.

In light of the non-deliverability of the sites that have already been assigned, it is believed that the Council will be unable to demonstrate a five year supply of deliverable sites starting from adoption in 2023. In addition, we anticipate that the Council will continue to fall short of the minimum five-year needs from 2025 to 2030 and from 2030 to 2040 based on the ‘steps’ in its proposed housing trajectory.

This has a clear correlation to the trajectory of the Council and its severe reliance on large-scale strategic locations for growth. The expectations of proposed delivery rates from new settlement-related growth at Little Barford and Kempston Hardwick from 20374/38 onwards (at a combined 1,200 units per annum) are wholly unprecedented and wholly unsupported by the evidence base.

Taking this background into account, the Council’s proposed reliance on a stepped trajectory directly contravenes national planning practice guidance where any such approach should not seek to unnecessarily delay meeting identified development needs and where stepped requirements will need to ensure that planned housing requirements are met fully within the plan period (ID: 68-021-20190722). The starting point for this information must be provided from the Council’s assessment of deliverability and developability in the SHELAA, where PPG recognises that there is a requirement to provide a reasonable prospect that large-scale sites can be delivered within the timescales envisaged, taking account of known constraints (ID: 68-019-20190722). Evidence should also be presented on the timescales and rates of development to be assessed (ID: 3-022-20190722).

The Council is unable to adequately defend its reliance on a stepped trajectory because it has not given enough consideration to reasonable alternatives or the related concern of ensuring that all sites are objectively assessed in terms of their suitability rather than excluded on general grounds of inconsistency with the chosen strategy. This is due to the strategy's reliance on a stepped trajectory and the Council's inadequate consideration of reasonable alternatives or recognition of the disbenefits of a strategy that defers growth until later in the plan period.

The content and evaluation of the suggested stepped trajectory are severely circumscribed under paragraph 9.14 of the April 2022 Sustainability Appraisal report. Cross-references in this sentence seem to be in the wrong place because paragraph 8.29 clearly refers solely to the evaluation of the Kempston-Hardwick new settlement. In other places, the SA only explains the justification for using a stepped approach at paragraph 7.24, and paragraph 8.33 deals explicitly with the choice and testing of a "stepped" alternative (with details provided at Appendix 8 of the report, incorrectly referenced in this paragraph as Appendix 9). Even though paragraph 8.33 claims that both methods have been studied and finds no drawbacks to a phased approach, this does not seem to be supported by the details subject to assessment.

Appendix 8 contains only a ‘stepped’ scenario, which would imply all other strategy options have been considered on the basis of being ‘un-stepped’. This is plainly incorrect and contrary to the Council’s generation of strategy options, where it has been clear throughout that Options 2a-2d (rail-based growth and A421 corridor) are only feasible using a stepped trajectory. These options would not otherwise comprise reasonable alternatives for meeting requirements within the plan period (although may do so under a hybrid strategy if complemented by further growth in the rural areas).

In light of this, paragraph 9.14 aims to support the Council's earlier reasoning for a stepped trajectory. The fact that there is a large blank space after this conclusion shows that the Council has not given any particular reasons why an un-stepped method should be rejected, which is necessary to support the selected strategy.

For instance, claiming that the stepped approach does not have the potential to have negative effects if the housing requirement is not fully met and that the chosen strategy has a negative impact on opportunities under SA Objectives 12, 13, and 14 relating to community cohesion and social infrastructure is not justified. This is demonstrated by the fact that the selected strategy has not enabled a detailed assessment of our client’s Land East of Station Road, Oakley and the associated opportunity for the expansion and enhancement of services at Lincroft Academy.

Likewise, there is no recognition that these dis-benefits can only be countered by looking at reasonable alternatives that Council has identified but excluded because it considers them ‘inconsistent’ with the selected strategy option. This would act against the Council’s reasons to reject these options and it is clear that there is a lack of meaningful assessment and rationale in relation to effects arising from the use of a stepped trajectory.

Therefore, as drafted, we consider that Policy DS3(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.

Object

Representation ID: 10363

Received: 29/07/2022

Respondent: Renhold Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing and Employment growth calculations
Policy DS3(S) on Page 28 anticipates a total of 27,100 new houses being built during the period 2020 – 2040, it is noted that this will bring 63% of new houses being delivered in the period 2030 – 2040. Policy DS4(S) outlines the calculations that a total of 26,700 new jobs being created by the end of the draft Plan period. Having an employment provision, which is inline with the new houses provision does not seem logical. There is no known employment or housing crisis in Bedford borough that would therefore require one or both of the employment or housing figures to have been calculated to produce such an unusual trend of such a similar supply need for both. The data shows an additional 26,700 jobs being created during the life time of the Plan represents a 34% increase over the current workforce, which appears to be unrealistic

Comment

Representation ID: 10386

Received: 29/07/2022

Respondent: Bletsoe Parish Council

The Parish Council does have some concerns and, in particular, in relation to the timing of housing growth. In this regard, policy DS3(S) identifies that over 62% of growth is profiled in the period from 2030. Whilst the reason for the late profiling of growth, due to dependency on the delivery of infrastructure is recognized, it is a concerned that delay in realising the development potential could affect the five-year land supply position with obvious consequences. A second concern is that the Government Guidance on the Standard Method for assessing housing need and calculating the housing target upon which the plan is based puts Bedford Borough in and anomalous position. The government is insisting that local planning authorities calculate housing targets through a formula that uses out of date data from the Office for National Statistics. This has a huge impact on the calculation of housing need for Bedford Borough and results in a massively inflated and unjustified target for future housing growth in this draft plan.

Object

Representation ID: 10417

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The current Core Strategy identifies, Great Barford as containing 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area'. The strategy alighted upon for the Regulation 19 plan however, whilst continuing to identify the role of Great Barford as a Key Service Centre, does not seek to identify a single additional home to the village, beyond that already committed through the current Core Strategy and identified via the Neighbourhood Plan.

Objection is raised to the overarching spatial strategy's reliance on a limited number of large sites to deliver the new homes required for the Borough. This is at the total exclusion of growth within sustainable settlements such as Great Barford, which are capable of accommodating additional growth on smaller sites well related to the urban fabric. These would be capable of early delivery, thereby avoiding the need for a stepped trajectory, and would meet need both when it arises, and within sustainable locations.

Objection is raised to the Local Plan Policies DS2(S), DS3(S) and DS5(S), on the grounds that these key policies embed an unsustainable growth strategy for the Borough, which fails to have regard to the evidence base, and which fails to follow through on the recognition of the settlement hierarchy, notably, larger villages such as Great Barford, which are identified as Key Service Centres and for which no new allocation is made for the plan period. In this case, the provision of a stepped trajectory, thereby denying the requirements of those in housing need today, is considered to be an unnecessary deferral of delivery. It also requires a significant uptick on historic delivery rates, over rates achieved in recent years. A strategy which draws on some smaller/medium sized sites, capable of faster delivery, would be more sustainable as p art of an overall balance which might still favour longer term delivery through large sites.
Lone Star have concerns regarding the reliance within the Regulation 19 Local Plan on use of a stepped trajectory, as set out in Policy DS3(S). 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 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.

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 National Planning Policy Framework ("NPPF") does not support the deferral of meeting the known housing requirement to beyond year 10. Planning Practice Guidance (68 - 0 21) 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.

To achieve this objective of national policy guidance, to meet the housing requirement with positive site allocations in years 1 to 10 of the plan or at least broad areas of growth from beyond year 5, the plan should balance away from such a heavy reliance on freestanding large new settlements. Currently, the Reg 19 plan speculates that the step might shift from 970 dw/yr up to 2030, with 1,5700 dw/yr beyond 2030, i.e. deferring 17,000 of the Plan's 27,10 0 dw requirement to later in the plan period.

The Council are therefore invited to review the trajectory of delivery for their Regulation 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 should 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.

For the above reasons the identified Policies DS2(S), DS3(S) and DS5(S), are considered unsound as they are neither Positively Prepared, Justified, Effective, nor consistent with National Policy .

Object

Representation ID: 10435

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy. The approach is not legally compliant in respect of the Sustainability Appraisal and Duty to Cooperate processes and fails all four soundness tests.

These comments should be read in conjunction with our clients Regulation 18 representations (Representation ID: 8572 / Site ID: 1247) which are appended to a Site-Specific Representation and which provides detailed comments on the proposed strategy and specific details relating to our client’s land interests. In addition to the Site Specific Report, which contains an updated Site Analysis Document showing how the site could deliver up to 120 dwellings, these representations should be read alongside the supporting Spatial Strategy and Legal Compliance Report.

The Site Analysis Document and Regulation 18 representations detail how the site could deliver the green infrastructure priorities set out in adopted (and proposed saved) policies AD24 and 36S. It is within the context of a site capable of delivering meaningful residential development in the Kempston Rural area, that these representations are made.

The Council's trajectory for the Local Plan 2040, as it is currently envisioned, will exacerbate current problems with the slow and delayed delivery of allocated sites, rendering even its suggested "stepped approach" to housing requirement ineffective. This is due to an overreliance on strategic scale development. The Council's position is seriously undermined by the lack of sufficient data to demonstrate that rail-based expansion in the A421 corridor is feasible, deliverable, or developable before years 11 through 15, if not sooner (and at the delivery rates indicated).

This creates a problem with supply that arises very immediately and can only be sensibly managed by dispersing development via small- to medium-sized sustainable sites throughout both urban and rural settlements. According to the NPPF and NPPG guidelines, allowing for a "hybrid" growth strategy, as regularly recommended by our clients, will assist prevent market saturation and improve settlement vitality.
We object to this policy. The approach is not legally compliant in respect of the Sustainability Appraisal and Duty to Cooperate processes and fails all four soundness tests.

These comments should be read in conjunction with our clients Regulation 18 representations (Representation ID: 8572 / Site ID: 1247) which are appended to a Site-Specific Representation and which provides detailed comments on the proposed strategy and specific details relating to our client’s land interests. In addition to the Site Specific Report, which contains an updated Site Analysis Document showing how the site could deliver up to 120 dwellings, these representations should be read alongside the supporting Spatial Strategy and Legal Compliance Report.

The Site Analysis Document and Regulation 18 representations detail how the site could deliver the green infrastructure priorities set out in adopted (and proposed saved) policies AD24 and 36S. It is within the context of a site capable of delivering meaningful residential development in the Kempston Rural area, that these representations are made.

The Council's trajectory for the Local Plan 2040, as it is currently envisioned, will exacerbate current problems with the slow and delayed delivery of allocated sites, rendering even its suggested "stepped approach" to housing requirement ineffective. This is due to an overreliance on strategic scale development. The Council's position is seriously undermined by the lack of sufficient data to demonstrate that rail-based expansion in the A421 corridor is feasible, deliverable, or developable before years 11 through 15, if not sooner (and at the delivery rates indicated).

This creates a problem with supply that arises very immediately and can only be sensibly managed by dispersing development via small- to medium-sized sustainable sites throughout both urban and rural settlements. According to the NPPF and NPPG guidelines, allowing for a "hybrid" growth strategy, as regularly recommended by our clients, will assist prevent market saturation and improve settlement vitality.

We believe that greater levels of small to medium sized growth such as that at Green End, Kempston, must be encouraged from the start of the 2020–2040 plan period in order to accomplish the goals of the forthcoming Local Plan 2040. The sustainability of locations well-related to the urban area, as the Council recognises, and in particular the determination that our client's land interests are suitable, available and achievable to support expansion that would provide contributions to sustainable development as favourably assessed in the Sustainability Appraisal (including new green infrastructure).

The Council's suggestion to adopt a stepped trajectory is a response to prior planning mistakes as well as general worries about the suggested spatial strategy and reliance on large strategic areas for expansion. In order to continue with the annual requirement in the adopted Local Plan 2030 for the purposes of ostensibly demonstrating a Five-Year Supply upon adoption (at least under the Council's figures), the proposed approach represents a mathematical sleight of hand. It does not make a fundamentally unsound plan "sound." The stepped trajectory represents an admission that the Council’s current planned strategy (and identified provision) cannot achieve a boost in housing supply and does nothing to overcome the legitimate concerns that constraints to the deliverability and developability of sites identified beyond 2030 will substantially preclude achievement of the housing requirement in the plan period.

Because the Council have not given enough thought to reasonable alternatives or the related concern of ensuring that all sites are objectively assessed in terms of their suitability rather than excluded on general grounds of inconsistency with the chosen strategy, the Council is unable to adequately defend its reliance on a stepped trajectory. This is because the strategy is based on the use of a stepped trajectory, and the Council has not given enough thought to reasonable alternatives.

It is evident that there is a lack of a meaningful evaluation and reasoning at paragraph 9.14 of the April 2022 Sustainability Appraisal report relating to the stepped trajectory, the assessment of non-stepped options and without any recognition of the dis-benefits of deferring meeting housing need. This aspect of the Sustainability Appraisal is severely confined in its content and has blank space where evidence to support the approach would be anticipated.

A revised Deliverability Assessment produced on behalf of our client challenges the Council's ability to demonstrate a sufficient supply of housing throughout multiple 5-year intervals of the overall plan period is submitted alongside these representations. If computed in accordance with national policy, as is demonstrated in the accompanying Assessment, we do not consider that the Council will be able to demonstrate a 5-year supply of deliverable sites upon adoption. We also assume that the Council will remain in its current status from 2025 to 2030 and 2030 to 2035. This is directly related to the Council's trajectory and its extreme overdependence on strategic size awards, which are known to produce results at a far slower rate than small and medium scale growth.

Therefore, as draft we consider that Policy DS3(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.

Object

Representation ID: 10441

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criterion (iii) of Policy HOU17 states that the development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan. Criterion (iv) requires submission of a transport assessment including measures to mitigate the impact of development on the local and strategic route network and to maximise opportunities for sustainable travel including provision of a mobility hub (criterion v).
Linked to this site specific policy, is strategic Policy DS3(S), which explains that housing provision across the plan period will need to be “stepped”; continuing at the same rate as it is for Local Plan 2030 for the first five years, with more significant growth post-2030 once critical infrastructure is delivered – in particular transport infrastructure. We have provided a detailed overview of the transport evidence that accompanies the Draft Plan in Appendix A of these representations.
Firstly, the Council should look to ensure that it seeks to meet housing needs consistently across the plan period and not unnecessarily pushing back housing delivery through the use of
a stepped trajectory, as outlined in paragraph 68-021of PPG. The use of a stepped trajectory should be a last resort and preference should be given to meeting needs more consistently across the plan period where sustainable.
The Council has identified that development of the Site at College Farm would be directly supported by the proposed improvements to the junction of A421/A600, which includes the introduction of traffic signals on the northbound approach of A600 leading towards the southern roundabout of the dumbbell junction. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 at that junction, we are of the opinion that a ‘Monitor and Manage’ approach should be adopted, in conjunction with the wider and more extensive improvements to widen A421 between A421/A6 and A421/A603 Cambridge Road.
The implementation of an improvement to the junction of A421/A600 should not prejudice either the commencement or the full occupation of dwellings on the Site. The adoption of a ‘Monitor and Manage’ approach would therefore be consistent with the current views of both National Highways and BBC, and any future highway scheme to improve the junction should be assessed as part of the more extensive proposal by National Highways to widen A421.
For the above reason, there is opportunity for College Farm to come forward earlier than anticipated in the Council’s stepped trajectory under Policy DS3(S) and this would go some way to addressing the shortfall in housing supply in the earlier plan period. Currently, the trajectory shows the first homes on College Farm occurring in 2028 due to the timing and need for upfront transport interventions on the A600/A421. We would argue that new homes could be delivered as early as 2025 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

Object

Representation ID: 10443

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM3(S) (Housing Mix) requires all developments of 20 dwellings or more to provide a minimum of 4% of all market housing and 6% of affordable housing to Category 3 standards. However, it does not clarify if such housing should be ‘wheelchair adaptable’ or ‘wheelchair accessible’ as both types exist under this standard.
We would expect application of Category 3 ‘wheelchair adaptable’ standards to apply to market homes and ‘wheelchair accessible’ standards to apply to affordable homes where the council is responsible for nominating the person who lives in that house.

Object

Representation ID: 10469

Received: 29/07/2022

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Please see accompanying Representations Report Paragraphs 3.35 – 3.39

MAT objects to this policy on the basis that the proposed approach unnecessarily delays meeting housing need and more specifically the identified requirements for expansion at Lincroft Academy. This is inconsistent with PPG ID: 68-021-20190722 and development that prioritises delivery of the required expansion and improvements should be supported as a solution to the unreasonably ‘stepped’ trajectory.

Object

Representation ID: 10500

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management supports the approach to the level of housing growth required, which as a “starting point” is set at 1,355 dwellings per annum and represents a significant uplift from the Local Plan 2030 requirement of 970 dwellings per annum. The level of growth also represents a further increase from the 1,275 dwellings per annum identified in the Draft Plan Strategy Options and Draft Plan consultation (see para 3.2).

In context, however, of the scale of uplift required and significant challenges in terms of housing delivery, Hallam objects to the proposed stepped trajectory, which is considered to be inappropriate for achieving an even and consistent level of housing delivery to meet the Borough’s housing needs. In this context Hallam considers that the plan does not meet the tests of soundness.
The amount and timing of housing growth example suggested in the Policy seeks to provide for 27,100 new dwellings with the delivery of 970 dwellings per annum until 2024/25 then stepped to 1,050 dwellings in the period 2025/26 – 2029/30 and then 1,700 dwellings per annum from 2030/31 until 2039/40. The stepped trajectory equates to a significant uplift in housing delivery, first by a modest 8.2% after 2024/25 and then by a substantial 61.9%after 2030/31. It builds in the postponement of measures to meet immediate need, and it increases substantially the level of risk built into the plan since the effects of any under-delivery of stepped housing requirements on housing need would be greatly exacerbated. There would be little opportunity to redress any under-delivery in the highly stepped targets at the end of the plan period.
Evidence, in Bedford Borough Council’s interim Housing Monitoring Report 2020-21 demonstrates that rates of housing delivery from 2015/16 to 2020/21 have ranged between 964 dwellings per annum and 1,359 dwellings per annum but overall, have supported the delivery of housing at an average rate of 1,192 dwellings per annum – well above the 970 dwellings per annum planned for up to 2024/25 and the 1,050 per annum planned for up to 2030.
Hallam considers that planning for a rate of delivery constrained to 970 dwellings in 2020/21-2025/26 and with just a modest increase to 1,050 to 2029/30 would be a constraint to growth, well below current delivery rates. With a lack of planned deliverable sites that could be brought forward sooner, a reduced rate will create a significant cumulative underbuild towards 2030/31. Such an approach, in turn, is likely to undermine wider growth and planning objectives. Failing to plan adequately for a sufficient supply of sites to come forward in the short and medium term, in the face of current higher delivery rates, and with sites in sustainable locations that are available to come forward if they are allocated, runs counter to paragraph 68 of the NPPF. Planning for lower rates will frustrate and provide no incentive to deliver sustainable development and growth opportunities in the early years of the Plan.

Object

Representation ID: 10515

Received: 29/07/2022

Respondent: Liz Calvert

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Unsustainable Housing Numbers

1. The vast numbers that this Plan commits BBC to is based on very uncertain ground. The demand for housing and jobs is not at all related to the likely population change in the area or even nearby demend. The recent Census proves this – existing growth is already increased by the building houses under earlier plans and the advertising of these well beyond our area. ORS Opinion Research Services, pointed out that existing planned in migration (HNA p 74 para 6.16) was already notable and that the extra 8877 dwellings represented as increase of 88% over and above that included in the most up to date household projection.

2. Housing needs are projected in an inefficient and inaccurate way – that even Mr Gove admitted. In addition, targeting Greenfield out of convenience and the profits of developers is extremely short-sighted and a poor management of resources.

3. The inflated number of houses is explained by the concept of the Ox Cam Arc – illustrated in PfP (Parnering for Prosperity) and finalised in A new deal for the Cambridge, Milton Keynes, Oxford Arc (NIC National Infrastructure Commission). This has now lost the support of the Department for LU H and C. Since it is also unlikely that the EW Rail will be completed, then the basis of much of this plan would need to be redrawn. Why, anyway, does BBC have far more new homes to target than than other parts of the Arc region?

4. The department of housing obviously has to face a housing supply commitment, but the vast number of houses built so far in this area are not addressing the real housing need as very little social housing is provided (not affordable housing but most even under that name are not for the majority of those in need.

5. The Local Authority should continue to stand up for an area which is taking far more than its fair share of development without even discussing this issue with local residents.

6. Natural Environment Policies – loss of valuable green areas, not environmentally sustainable.

The National Planning Policy Framework (NPPF) (2021) Para 174, states that ‘Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Using these and the three additions to the document which add a new emphasis on tree numbers and protection, tackling climate change and producing design codes, then the impact of the 2040 Plan is not environmentally sustainable.
The idea that ‘man-made river parks (Great Ouse) is better than the already largely accessible and ‘natural’ Gt Ouse Valley is strange. The Waterway planned would be pleasant for those using the canal but its construction removes natural landscape in the process. This does not appear to enhance natural environments.

Local environments that already exist are often greatly impacted. Small settlements are surrounded by completely different views and the character of their environment changed forever. One natural area has its biodiversity connection etc removed and there is increased pollution – noise, visual and air pollution.

7. Defra’s Nature Recovery Network NRN and their National Food Strategy also are in conflict with these plans. All too often good farmland is lost, natural landscapes which help to protect us from climate change. Huge depots which serve our desire to consume but do not provide many jobs (and often unpleasant conditions for employees) remove even more natural environment which is gone for good.

8. Soundness
There is much overlap with previous points so I will simply mention water and existing infrastructure.
Bedfordshire is one of the driest counties in the country. The current near droubt is showing what happens as climate is also changing. The situation gets worse while we plan to increase the housing dramatically and cover over land which benefits water supply and helps to prevent extreme high rainfall events.

Sewage – there are all to many examples or water authorities in the area not coping with existing volumes and very often discharging into local rivers. . How can we cope with more?

Social Infrastructure – Even if this is addressed to some extent, BBC area already has a dreadful situation as far as numbers of doctors are concerned. The Mayor himself has discussed this. Can we not improve that experienced by existing residents instead instead of making it worse for them?

Comment

Representation ID: 10528

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS3 (Amount and Timing of Housing Growth) states that a provision of 27,100 new dwellings will be stepped as follows:
(extract table from DS3)
In order to support the policy, a stepped trajectory topic paper has been published as part of the Council’s evidence base, which seeks to illustrate why a stepped trajectory is justified. The paper states that the BBLP2040 requires a stepped trajectory as a result of the Standard method, which requires a 40% increase in the Borough’s housing delivery rate, when compared to the Local Plan 2030. The local plan strategy of an urban focus with rail-based growth is also set out as a factor, as it necessitates the delivery of large strategic sites with longer lead in times.
Whilst these factors are acknowledged, the principle of a stepped housing trajectory is not accepted. The Council should be ensuring that the housing needs are met at a consistent rate throughout the plan rather than deferring until later in the plan period, particularly when the resultant impact will be delivery later in the plan period of a scale which has not been achieved in the Borough in the recent past.
We agree that larger sites take significant lengths of time before development commences and optimum rates of housing delivery are achieved. The PPG provides further information on when a stepped housing requirement may be appropriate for plan-making (Paragraph: 021 Reference ID: 68-021-20190722). Whilst it acknowledges the reasons set out within the background paper, it states that stepped requirements will still need to ensure that planned housing requirements are met fully within the plan period, in order to avoid delays in meeting identified development needs.
Due to the uncertainties which surround the delivery of the major infrastructure on which the large strategic sites depend and given the viability challenges highlighted on some of the allocated ‘urban’ sites, the Local Plan should allocate sufficient smaller non-strategic sized sites in locations other than Bedford urban area to complement larger sites and to ensure HLS in the early to mid-term. In order for the strategy to be ‘sound’, 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 still have uncertainties and 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 which are less likely to come froward within the timescale envisaged.