Issues and Options

Yes

The scope of the Local Plan Review appears to cover most of what would be expected, however there are two additional points that Storey Homes proposes Bedford Borough Council should consider: • Whether the Council should commit to another ‘early review’ within 3 years of adopting the Local Plan Review • The need to update the affordable housing policy to reflect any national changes On page 6 of the Consultation Paper, the Council acknowledges that “little progress has been made on how the high-level ambitions for the Arc can or will translate into identifying where strategic growth is likely to be delivered.” Given this lack of progress and the uncertainty regarding the extent to which any progress will be made between now and 2023, the Council are likely to be producing this Local Plan Review with only a small degree of additional knowledge on this topic, in comparison to the information known during the Local Plan 2030 process. The Council therefore will not be able to fully understand how the Arc ambitions will affect their strategic growth. In light of this, it is suggested that the Council consider committing to another ‘early review’, 3 years from the adoption of this Local Plan Review, to once again reflect on any progress related to the Arc. The “Changes to the current planning system” national consultation remains open until 1st October 2020, following this, it is expected that a series of changes will be implemented towards the end of 2020/start of 2021. This may include a new requirement for a minimum of 25% of all affordable housing units secured through developer contributions to First Homes. First Homes are provided at a 30% discount on the open market price. Should this requirement become enshrined in national policy, the Council should update their local policy accordingly. This consultation also considers raising the unit threshold at which point affordable housing is a requirement. Although this is likely to be a temporary measure, this could change, and the Council should update their affordable housing policy as necessary.

The draft vision pinpoints a series of specific projects to be completed, including East West Rail and the Stewartby Brickworks redevelopment. These appear more like objectives rather than the vision, which is typically more overarching in its remit.

I do not agree with this plan period

The plan period should be 2020-2040 in accordance with Government policy. As mentioned in our response to Q1, the Council should consider if there is a need to commit to an ‘early review’ of this Local Plan Review due to the continued uncertainty regarding the Oxford to Cambridge Arc.

Brown – Urban based growth , Yellow – A421 based growth , Pink – Rail growth , Orange – East-West rail northern station growth , Grey– Dispersed growth , Red – New settlement based growth

We support the continued sustainable growth of Bedford Borough and would welcome a combination of the outlined growth options. Some more general comments upon the scale and location of housing growth are set out as for your consideration. Housing Need Page 16 suggests that the per annum housing figure could range between 800 and 1,305 homes. The 1,305 homes requirement is based upon the current standard methodology and represents the minimum number of units that Bedford should plan for in accordance with adopted national policy. The Council suggest that the revisions to the standard method, may result in a decrease in their minimum housing requirement potentially bring this down towards 800 units. However, the proposed revised standard method calculation would result in Bedford’s housing requirement being set at circa 1,153 dwellings per annum. This revised standard method calculation is still being consulted upon and it is likely that further amendments to this may be made, thus it cannot be wholly relied upon at this stage. Nevertheless, it would be sound to conclude that Bedford’s housing requirement will increase from the Local Plan 2030 requirement of 970 units per annum and is far beyond 800 units per annum. At the present time, the Council should plan for the provision of 1,305 units per annum in accordance with the current standard method. We would suggest that even if the revised standard method does reduce the minimum requirement, the Council maintains its approach to provide 1,305 units per annum. By planning for a degree of ‘over-provision’ this will ensure the Local Plan is more robust against future changes in housing supply requirements and can comfortably meet its minimum need. Small - Medium Sites Storey Homes are proud to be a privately owned family business operating across the South East and currently delivering two major developments in Bedford Borough. We are a Small/Medium Enterprise (SME) housebuilder with the capacity and capability of meeting current and future housing needs across the Borough. We currently deliver projects ranging from 12 to 100+ units, these developments are in the form of either a well-located small-medium site or a parcel that forms part of a wider Sustainable Urban Extension (SUE). As such, we would support both the allocation of small-medium sites as brownfield, infill or proportionate village extensions and SUE’s, but would advocate that SUE’s are designed so that small-medium parcels can be released for SME housebuilders to build out. The importance of small-medium sites is recognised at paragraph 66 of the NPPF (2019) which states that “small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out very quickly.” The Council must ensure that spatial strategy will not prevent the Council from delivering the objective set out in paragraph 68 of the NPPF which requires at least 10% of its housing supply to be delivered on sites no larger than one hectare. These can be identified either in the Council’s Brownfield Register or in the local plan itself, but they should not be part of an assumed level of supply within windfall estimates. We would support 10% of the Local Plan allocations being for small sites, this reduces the risk of developing such sites for SME housebuilders. Further to this, the Council should also look to allocate ‘medium’ size sites of 2-5 hectares, the allocation of sites of this size, this would benefit more established/larger SME housebuilders whom are able to deliver units at a major scale, but are not a typical volume housebuilder. Overall, provision of a range of site sizes and types at a variety of sustainable locations (including within or adjacent to rural communities), will bolster Bedford’s housing supply and ensure a variety of house types will come forward in the Borough.

I agree

As members of the House Builders Federation, their consultation response on behalf of the industry has been shared with us prior to submission. We support their response to this question and do not wish to add further comment.

I agree

As members of the House Builders Federation, their consultation response on behalf of the industry has been shared with us prior to submission. We support their response to this question and do not wish to add further comment.

As members of the House Builders Federation, their consultation response on behalf of the industry has been shared with us prior to submission. We support their response to this question and do not wish to add further comment.