Issues and Options

RE: LOCAL PLAN REVIEW: ISSUES AND OPTIONS CONSULTATION 1. Introduction I write on behalf of Barratt David Wilson Developments Ltd (‘BDW’) who welcome the opportunity to comment on the Issues and Options Consultation which will form part of the Local Plan Review. BDW are the Nation’s largest homebuilder providing quality homes for a variety of customers with properties ranging from those for first time buyers to large luxury family homes. BDW have been rated a Five Star Homebuilder for 11 consecutive years (HBF Customer Service Survey). As a homebuilder, these representations only relate to parts of the document directly related to the delivery of homes and associated infrastructure. BDW have successful delivered a number of Developments within Bedford Borough including Great Denham and Wixams (split between Bedford and Central Bedfordshire). Each of the relevant consultation questions or topics have been addressed in turn below: 2. Housing supply The document states that the emerging plan would need to accommodate 26,100 dwellings, based on the 1,305 dwellings per annum as calculated in accordance with the current standard method. However, NPPF and Planning Practice Guidance recognises this figure is a minimum and there are circumstances where Local Planning Authorities may need to plan beyond this minimum. The Council has not considered whether there are unmet housing needs in neighbouring areas that must be addressed, in accordance with paragraphs 11 and 60 of the NPPF. When considering, Bedford’s location on the strategic rail network the consideration of unmet need may go beyond adjoining Authorities. Therefore, consideration should be given as to whether the Borough can meet some of London’s shortfall. Bedford is within a reasonable commuting distance of London and with the likely shift to enhanced homeworking the Borough is able to address some of London’s shortfall. Furthermore, I would question the impact that Covid-19 has had on people’s lifestyles and whether the desire for larger properties, with private amenity space, would result in a new trend of people moving to commutable areas such as Bedford and the impact this may have on demand and consequently, affordability. In addition, the Council should consider options for delivering housing beyond its Local Housing Need Assessment (LHNA) in order to support the Oxford – Cambridge Arc. In the supporting text it is noted that Bedford is located at the centre of the Oxford – Cambridge Arc and benefits from new east-west transport links. The Council should embrace the Borough’s potential to deliver beyond the minimum requirements. The Council acknowledges, on pages 3 and 4, that one of the reasons for an early review was the Local Plan 2030 Inspectors felt there was a need for a plan which responds appropriately to longer term growth and in particular the Oxford - Cambridge Arc. It is felt that delivering the minimum as identified in the LHNA is not responding to the Inspectors’ concerns and the rationale for the early review. It is the view of BDW that the Council should plan for growth in this plan and not future reviews.

The draft vision should be expanded to address housing as the inability to access suitable housing, or high house prices, threaten the quality of life for the Borough’s residents. Currently, there is a national housing crisis, with record numbers of homelessness and high unaffordability as well as increasing overcrowding of properties. A vision for the Local Plan should be to ensure that there are sufficient homes that meet the needs of the Borough’s residents. The vision as currently drafted does not seek to meet this. BDW recommend that the following text is included within the vision: “Bedford Borough will provide a balanced range of high quality housing to meet differing housing needs and aspirations and offer an excellent quality of life for its communities In addition, the vision does not seek to embrace and capitalise on the Borough’s place at the centre of the Oxford-Cambridge Arc, which is an area of world leading universities and research institutions with a concentration of knowledge-intensive, technology and high performance engineering businesses. If planned for effectively, this will further boost the Borough’s economy. It is therefore, suggest that the following is incorporated into the vision: “The Borough will build on its economic strengths, including its location at the heart of the county and in the Oxford – Cambridge Arc.”

I agree with this plan period

BDW agree with the proposed plan period ending in 2040. This would ensure the plan is consistent with the minimum 15-year plan period for strategic polices as required by paragraph 22 of NPPF. However, we do question the start date of the plan being 2020, given the plan is unlikely to be submitted before 2023 and not adopted until 2025.

Nothing chosen

The consultation document sets out a number of potential locations for housing and employment growth. It is our view that growth should be directed to the locations that can facilitate sustainable development, whether that be a sustainable urban extension to an existing settlement or a new sustainable community. It is therefore, our view that the growth scenario should comprise all the following growth locations: - expansion of the Bedford/Kempston urban area; - further regeneration within the Bedford/Kempston urban area; - new settlements in locations with good accessibility - development around an East West Rail norther station; - development along the A421 corridor; - more dispersed development throughout the Borough including the expansion of villages; and, - expansion within the Borough boundary, of neighbouring urban areas, such as Rushden and St Neots. It is unlikely that any of these scenarios in isolation would deliver a sufficient number of homes, therefore, a combination of the scenarios set out above would ensure a wide variety of sites are allocated in sustainable locations. This would allow the Council to incorporate large scale strategic sites which have greater benefits through the provision of a social infrastructure to benefit both existing and new residents whilst ensuring a sufficient supply of medium sized sites (eg 100 – 500 dwellings) which can be delivered quickly and have a meaningful contribution to housing land supply, ensuring at least 10% of the housing supply is delivered on sites no larger than one hectare in accordance with the NPPF paragraph 68.

I agree

BDW are committed to supporting the transition to a low carbon economy which the UK is building, supported by the fact that in June 2020 BDW announced new carbon emissions targets as part of a drive to become the Country’s leading national sustainable homebuilder. A national and standardised approach to improving the energy efficiency of buildings, the provision of renewable energy and electric vehicle charging points is considered the most effective. However, should the Council feel it appropriate to set out detailed policies to address the issue of climate change then they should be within the context of the current policy, legislative framework and technical standards as set out in paragraph 150 of the NPPF. The importance of a collective approach will also balance the cost of delivering the energy efficiency improvements required alongside other planning obligations (affordable housing, highways improvements, CIL etc) and development aspirations that the Council are seeking to deliver. As such, the Council will need to ensure that any policy requirements to do not render the Development unviable. When drafting climate change policies the Council should clearly set out their expectations in terms of the following: - The triggers for certain types of development requiring climate change adaption, for example, a justified evidence base for both residential and commercial triggers. The Council need to take into account the requirements of Building Regulations Part L, anything over and above building regulations would not be considered justified; - Be explicit on the requirements for renewable energy, taking into account the viability of development; - Decentralised electricity supply needs to be considered in the context of Ofgem regulations as Occupiers are required to have choice of suppliers; - When setting a percentage of carbon reduction consideration should take into account brownfield and greenfield characteristics. Will there be a carbon offset fund? Will there be a user friendly tool kit to calculate carbon reduction? - If fast vehicle charging points are to be proposed, has there been any assessment of the current electricity network able to take the load capacity of fast charging? As such, will there be a requirement for Developers to contribute to electric infrastructure in the wider catchment of the site and, if so, what are the implications on viability? 7. Viability Viability of development is critical to the success of the plan, if policies are so onerous that development is rendered unviable it will delay the delivery of development. The NPPF paragraph 57 states; “that where up-to-date policies have set out the contributions expected from development, planning applications that comply with them should assume to be viable.” This places the emphasis on viability at the local plan stage opposed to during the determination of a planning application. It is important that the cumulative impact of policies is considered when assessing the viability of schemes. When considering allocations, particularly large scale/strategic sites, consideration needs to be given to abnormal costs and factored into the viability using the best available information. The cost of delivering infrastructure, even when the cost can be deducted off the price of the land, may render a development unviable as it de-incentivises the Landowner when minimum values land values cannot be met.

BDW welcome the opportunity to engage with Bedford Borough Council at an early stage in the plan making process. It is BDW’s view that further consideration should be given to the Local Housing Needs Assessment, the Borough’s location within the heart of the Oxford- Cambridge Arc and implications that the Government’s growth ambitions will have on the Borough. Should the Council require any input from Developers in respect of delivery of homes and viability, BDW would be willing to participate. If you have any questions, or require any clarification on the content of this letter please do not hesitate to contact me on the below email address.