Plan for submission evidence base

Comment

Representation ID: 10084

Received: 28/07/2022

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Reflecting on the inability of the council’s current proposed trajectory to deliver sufficient new homes to meet its LHN prior to 2030 (our Enclosure 2) and considering the clear difficulties faced in the delivery of five of its key town centre sites beyond this point (our Enclosure 1) it appears critical that the submission version of the Local Plan 2040 seeks to include our client’s land between Hookhams Lane and Ravensden Road, Salph End for a residential development of up to 400 dwellings, land for a new primary school along with public open space and green infrastructure.

The location and extent of the site is shown below: (map)

Our client’s land has been promoted consistently towards both the adopted Local Plan 2030 and now towards the Local Plan 2040. This included two separate submissions towards the council’s Call for Sites comprising our client’s initial response in August 2020 and an addendum submission following the outcome of an appeal at the site in January 2021. Combined, these submissions have informed the council’s Call for Sites Assessment which concludes that our client’s land is devoid of any legal, environmental, or technical constraint. Specifically, the assessment included as part of the evidence base of the plan includes the following key conclusions:

• It is within acceptable walking distance of a full range of shops, services, facilities and amenities (most within 0-10 minutes’ walk);
• It adjoins the urban area and/or an existing settlement policy area so is not detached from existing built form;
• Its development would not have a harmful effect on the landscape (a conclusion of neutral);
• It is not at risk of flooding, nor are there any on-site environmental or physical constraints which would preclude its delivery; and
• There are no local highways or junction capacity issues that would require the delivery of significant off-site infrastructure.

Indeed, it is clarified by the site assessment that the previous concern that precluded it from allocation in the Local Plan 2030 – that is coalescence – has now been resolved to the satisfaction of the council. Indeed, it confirms that it has now only been omitted from the current Regulation 19 draft of the plan due to its conflict with the preferred development strategy. As is made clear by our Enclosures 1 and 2 the current development strategy is deeply flawed.

Once again, we are therefore pleased to confirm that the site is:

• Available: The site is being actively promoted by our clients, Manor Oak Homes, who wish to use this submission as an opportunity to once again state the availability of the land for allocation in the emerging Local Plan and indeed for immediate delivery;
• Suitable: The site is in an entirely suitable location for a residential-led development being immediately adjacent to the Bedford urban area and the Settlement Policy Area of Renhold/Salph End, this being evidenced by the Council’s decision to identify it as a possible allocation in an early iteration of the now adopted Local Plan 2030 and then as clarified by the conclusions of the appeal Inspector in December 2020; and
• Deliverable: The site is devoid of any constraints and capable of contributing towards the housing and infrastructure needs of Bedford Borough in the first 5-years of the plan period. In addition, the land is promoted by Manor Oak Homes, a company with a strong track record of securing implementable residential and mixed-use planning permissions that have in turn led to the delivery of a substantial number of large scale developments across the South East and Midlands.
In light of the above it is worth reminding the council of the remarkably candid remarks of the appeal Inspector who, despite dismissing the case on the grounds of prematurity, identified the land as an obvious and compelling development site that it is clear should come forward at the earliest opportunity. He stated at paragraph 12 of his decision:

“Nevertheless, the appeal site is not without its intrinsic merits in terms of the spatial strategy; it is adjacent to the defined Settlement Policy Area of Salph End; within walking distance of a local grocery store and post office, a public transport route and some other local facilities; and it would provide that settlement with education provision and open space facilities. Most of the site was included as an allocation in a consultation version of the Local Plan before its adoption. The eventual decision to exclude the site from the plan was judged by the Inspectors who examined the plan to be a reasonable one, although they note that the matter was clearly finely balanced. It is again included in options being considered in the current review of the Local Plan and so, it is not unreasonable for the appellant’s advocate to imply, as he does in his closing remarks, that it is a matter of when, not if, the site is to be developed.

It should be noted that our client’s land was considered as an almost identical form of development as the site subject of draft Policy HOU13 ‘Land at Gibraltar Corner’ during the preparation of the Local Plan 2030, that is as a sustainable extension to the urban area. It was subject of a draft allocation on the same basis as our client’s land and was similarly removed for the previous reason of harm to character (a matter now resolved in respect of our client’s land following the Section 78 appeal). Whilst the allocation of the land at Gibraltar Corner is once again justified based on its contribution to green infrastructure it is vital to note that our client’s own land would achieve the same, partially falling as it does in the ‘Bedford Northern Fringes Green Infrastructure Opportunity Zone’. In addition, our client’s site would secure the significant benefit of land for a new primary school, playing pitch provision and unlike the land at Gibraltar Corner would be first deliverable within the immediate 5-year period following the adoption of the Local Plan.

In respect of delivery and assuming a 2023 adoption we have modelled the development of our client’s land against the oft-cited Lichfields report ‘Start to Finish ’ which identifies that following the grant of planning permission the average annual build-out rate is 60 to 70 dwellings per year for sites of 100 to 1,000 dwellings. Based on the submission of a full planning application in 2023 we would expect work to start on site within 6 months of the plan’s adoption, so early to mid-2024. Using the upper end of the Lichfields range, and anticipating two developers on site, it is assumed that completions would take place at a rate of 70 per year. On this basis the development is capable of being delivered in full by 2029. These rates of delivery would ensure that the site is completed within the first 10 years of the plan period prior to 2030 when there is a critical demand for additional homes.

The expected annual delivery from the application scheme, factoring in the time until the grant of planning permission (PP), is set out in Table 3 below:

Table 3: Delivery Timescales of Site ID 822

20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 30/31
- - - PP 50 70 70 70 70 70

Based on the lack of any legal, technical or environmental constraints to our client’s land allied with both the critical need for additional homes across the Borough and its ability to be delivered swiftly there is no logical or rational reason to omit the land as an allocation in the plan.

Failure to allocate our client’s land would contribute towards a strategy which fails to be positively prepared, justified or indeed effective whilst conflicting with the national policy requirement to significantly boost the delivery of new homes.