Plan for submission evidence base

Comment

Representation ID: 9893

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

4. Housing Supply
4.1 Paragraph 1.3 of the Development Strategy Paper states:
“Over the plan period, in total, the Council will need to allocate land to enable a minimum of 27,100 dwellings to be delivered (20 x 1,355). Current commitments (including completions since 2020) amount to around 14,800 dwellings which means that land to accommodate in the region of at least 12,280 dwellings plus a reasonable buffer must be allocated in the new local plan.”
4.2 Paragraph 1.3 of the Development Strategy Paper states:
“Over the plan period, in total, the Council will need to allocate land to enable a minimum of 27,100 dwellings to be delivered (20 x 1,355). Current commitments (including completions since 2020) amount to around 14,800 dwellings which means that land to accommodate in the region of at least 12,280 dwellings plus a reasonable buffer must be allocated in the new local plan.”
4.3 The LPA’s 5 Year Supply of Deliverable Housing Sites 2021/22 to 2025/26 statement sets out the current position on the 5 year supply. A number of points arise:
• For the first 6 years of the plan period for the 2030 Plan there is a shortfall of 1,333 dwellings;
• The total supply in the 5 year period is 4,851 dwellings which comprises:
o 21/22 – 987 dwellings
o 22/23 – 994 dwellings
o 23/24 – 1,089 dwellings
o 24/25 – 969 dwellings
o 25/26 - 812 dwellings
• The total supply in the first 5 years of the trajectory in the 2040 plan (Appendix 1 of the Stepped Trajectory Topic Paper) is:
o 21/22 – 966 dwellings
o 22/23 – 977 dwellings
o 23/24 – 1,089 dwellings
o 24/25 – 952 dwellings
o 25/26 - 866 dwellings
• This totals 4,850. This is a shortfall of 1,995 against the standard method.
4.4 A key point is that the new allocations proposed in the 2040 Plan have made no change to delivery in the first 5 years of the plan period. This Plan is the opportunity to bring forward sites, particularly small and medium sized sites as required by paragraph 69 of the Framework or larger extension sites that can deliver early in the plan period and in full in the next 5 years. Our client’s two sites at Wootton and Biddenham can both deliver in the 5 year period.
4.5 Paragraph: 039 Reference ID: 61-039-20190315 of the PPG (What are the steps in gathering
evidence to plan for housing?) states:
“Authorities can use this evidence to:
• prepare or update their Strategic Housing Land Availability Assessment jointly with the authorities within the defined area or individually to establish realistic assumptions about the suitability, availability, and achievability (including economic viability) of land to meet the identified need for housing over the plan period, including robust evidence of deliverability for those sites identified for the first 5 years of the Plan
• prepare a viability assessment in accordance with guidance to ensure that policies are realistic and the total cost of all relevant policies is not of a scale that will make the plan undeliverable.”
4.6 Paragraph 68 of the Framework states that “specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan”. Developable is then defined as "sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.
4.7 The Executive Summary in the Viability Study states:
“Our assessment identifies that one of the six strategic sites tested (River Valley Park) is viable and deliverable with respect to the Council’s planning policy requirements (including affordable housing) at current costs and values. We note, however, it is viable only at the lower greenfield benchmark land value. The Council have identified additional infrastructure requirements to be provided in the River Valley Park strategic site, which our sensitivity testing has been shown to impact on the viability of the site. At current costs and values when the Watersports lake contribution is factored into our assessment, the site is unviable even at 0% affordable housing. The study identifies, however, that the site is viable and can accommodate the additional identified infrastructure and 30% affordable housing when growth in sales values and inflation in build costs are allowed for in the assessment.
We have also sensitivity tested lower levels of affordable housing and note that the Land East of Wixams and Gibraltar Corner sites can viably deliver 10% and 5% affordable housing when assessed at current costs and values and measured against the lower greenfield land value benchmark.
The two largest strategic sites (Little Barford and Kempston Hardwick) are identified as having challenging viability at current costs and values. However, in our experience of assessing the viability of such large schemes this is not unusual, and developers frequently rely on value growth through regeneration premiums and maturity factors to deliver them, particularly given the significant upfront infrastructure costs associated with their delivery, which can impact on cashflows.
Given the long timescales over which the strategic sites will be developed, the NPPF identifies in the definition of “Developable” sites in the Glossary at Annex 2, that it is reasonable and acceptable to factor in growth into the assessment of their viability. Our appraisals factoring in appropriate growth in sales values and inflation in build costs over the identified development periods demonstrate that all of the identified strategic schemes tested in this study are viable and therefore developable delivering 30% affordable housing.
We therefore consider that the identified strategic sites are developable and able to support the emerging LP2040 policy requirements. Further, the Council’s policies build in an appropriate level of flexibility i.e. Policy DM1 (S) (Affordable Housing) is applied subject to viability and allowing for future reviews of viability as the development progresses. This will ensure that the strategic sites can come forward and will deliver the maximum reasonable quantum of affordable housing and infrastructure contributions.”
4.8 This shows that the Plan is predicated on viability issues being addressed later in the plan period (by increased land values driven by increasing house prices) and if there are issues at that time then less (or no) affordable housing would be delivered. Figure 2.25.1 (Average house prices in Bedford Borough) show an increase from 2013 to 2021. That increase corelates with the ratio of median house price to median gross annual earnings as set out below.
SEE GRAPH IN ATTACHMENT
4.9 If that correlation remains, for the allocations to be viable house prices have to increase. As we set out under DS3 there is a significant and worsening affordability crisis in Bedford and the implications of the viability assessment is that it will worsen further in order to deliver these sites. Smaller and medium-sized sites that can viably deliver affordable homes now should have been prioritised.
4.10 To conclude, the evidence on the deliverability and developability of the sites in the trajectory does not form part of this consultation and a critical assessment of the sites must be undertaken as part of the Examination.

Comment

Representation ID: 9904

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

6. Land west of Hall End Road, Wootton (Site ID 371)
6.1 We set out below an overview of the site HSL are promoting for residential development in Wootton for up to 81 homes, however a reduced scale of development could be considered if necessary.

Site Location and Description
6.2 The site is generally rectangular shape, on the edge of the western built-up area of Wootton, which lies south west of Bedford. The site, as identified by the red line boundary, covers approximately 6.5 hectares (ha) or 16 acres.
SEE ATTACHMENT FOR SITE PLAN

6.3 The northern edge of the site is defined by Hall End Road (also National Cycle Route 51) and the John Bunyan Trail. There is a field access gate to the northeast corner of the site. From this direction, the settlement of Wootton has recently been expanded towards the site with the construction of 58 dwellings (Ref: 14/02939/MAF) (Allocation AD2) and is a prominent feature. An allocation for a school extension is also located north east of the site on the opposite side of Hall End Road and is yet to be implemented and extends the settlement edge outwards towards the site.
6.4 The eastern boundary runs alongside an unnamed road that provides access to Wootton Upper School and commercial/ farm premises. The southern boundary is contiguous with Wootton Wood, an area of ancient and semi-natural woodland. The western boundary is shared with an adjacent field, laid to pasture. These boundaries are all formed from native hedgerow with a combination of post and rail or post and wire fencing within.

Sustainable and Suitable Location

6.5 The village centre of Wootton is located approximately 900 metres to the east of the site. The village benefits from many amenities including local convenience stores, pubs and restaurants, several churches, a petrol station, pharmacy, public library and football club. The wider parts of the village contain community services such as the village hall, memorial hall, play areas, skate park and tennis courts.
6.6 In terms of transport links, bus services serve Wootton and can be accessed within a short walk of the site. These services provide regular daily services to destinations such as Bedford, Milton Keynes and other local villages, providing residents with the opportunity to access a wide range of employment, shopping, leisure and cultural opportunities without having to rely upon the private car. The site location therefore would accord with NPPF §110.
6.7 The Environment Agency Flood Maps show the site lies entirely within Flood Zone 1 indicating it has a low probability of flooding and is suitable for residential uses.
6.8 Wootton has a historic character, with buildings and monuments dating from as early as the 14th Century. Wootton Church End Conservation Area is located approximately 250 metres to the east of the appraisal site and encompasses the Grade I listed Church of St. Mary and several other listed buildings. These heritage assets are separated from the site by Wootton Upper School and so development of the site would not have a negative impact upon their setting. The westernmost part of the site is within an Archaeological Interest Site. The LPA also agreed in the committee report that there is no heritage issue.

The Proposed Development
6.9 This proposal submitted to the LPA sought outline planning permission for the construction of up to 81 dwellings with access. The final layout, scale, landscaping and appearance would be the subject of a reserved matters application. The proposed illustrative site layout and Design and Access Statement submitted with the application shows how the dwellings could be comfortably accommodated on the site along with open space and the conserved and managed meadow.
These are enclosed as Appendix EP1.
6.10 All of the proposed dwellings within the site would be served by a single access road which would be taken from Hall End Road. The main internal access road is shown and the precise details would form part of the reserved matters application. Pedestrian and cycle connectivity can be explored at the reserved matters stage.
6.11 The TA states that the proposed site is situated approximately 950m west of Wootton village centre, and coupled with the site’s proximity to frequently serviced bus stops, cycle routes and viability to access the nearest rail station, accessibility from the site is considered to be of a good standard with opportunities to promote sustainable travel from the site. A Travel Plan was also submitted with the application to help promote more sustainable choices of travel.
6.12 We note the highways comments in the HELAA which state:
“The site is a Greenfield site and located in the village of Wootton approximately 6 miles south-west of Bedford town centre. The sites proposed access is along Hall End Road and is reportedly considered acceptable by BBC highways through application 19/00894/MAO. There is moderate traffic congestion along Hall End Road and the development could worsen this. The nearest bus stop is located 550m away on Cause End Road. Acceptable footway is located on the opposite side of Hall End Road and it is also considered a bicycle friendly route. Provide crossing to the footway on the opposite side of Hall End Road. A Transport Assessment would be required to assess the impact of this scale of development on the local highway network”.
6.13 As we examine in the next section, whilst highways was a reason for refusal at the application stage, contrary to the advice of the highway authority, the Inspector found no highway issue.
6.14 With regard to the Site assessment conclusions, the HELAA states:
“The site has been excluded from further assessment at Stage 1 because its location is not in accordance with the development strategy.”
6.15 We have addressed this matter under Policy DS5(S).
6.16 I note that some local residents questioned the need for more housing in the village and suggested that Wootton has ‘reached the limit’. However, the housing figure is based on the Housing Needs Survey (2017) and NPPF section 5 confirms that it is the Government’s objective to significantly boost the supply of homes. Paragraph 11 of the NPPF confirms that a sustainable pattern of development should be promoted. I consider that the wide range of community facilities and services that are available in Wootton contribute significantly to its credentials as a sustainable location for development.

The Application and Appeal
6.17 Following their consideration of the proposal, the professional officers of the Council concluded that planning permission should be granted and recommended this to the planning committee on 28th October 2019. The application was deferred for a site visit and it was considered again on the 25th November. The members of the Planning Committee voted to refuse the application solely on highway grounds contrary to the advice of the planning and highway officers.
6.18 The committee report sets out the detailed 22 planning considerations that were examined and the planning officer was informed by statutory and non-statutory consultees and other consultation letters during the determination period with the conclusion that permission should be granted.
6.19 An appeal was submitted and determined. However, following a High Court challenge the Inspector’s decision on the appeal dated 15 September 2020 was quashed. The proposal has the following benefits:
• the delivery of open market housing to assist in boosting the supply of housing in Bedford and can meet the a locally-arising need identified in the evidence base for the WNP as well as borough housing needs;
• delivery of a medium sized site by HSL who have a proven track record of delivery which would accord with the clear objective of the Government in paragraph 69 of
the Framework.
• the development accords with the spatial strategy as expressed in Policy 3S of the Local Plan which identifies Wootton as a Key Service Centre which can accommodate strategic residential development in a sustainable location.
• the proposed development helps to meet the objectives set out in the Bedford Green Infrastructure Plan (2009) and the provision of open space to meet the needs of existing and proposed residents and maintain a Green Corridor as required by saved policy AD24.
• residential development at the site through the proposed scheme will result in an improvement to the biodiversity value of the site and the net gain benefits to be achieved and secured by the scheme outweigh the estimated loss of c. 3.1 hectares of the neutral grassland at the CWS to achieve compliance with the paragraph 180(c) of the Framework.
• the delivery of 30% affordable housing accords with Policy CP8 and would assist in addressing the very significant and persistent shortfall in affordable housing delivery. There is a significant shortfall of affordable homes since 2003 and there is a significant need going forward. There is also an identified need for 24 affordable homes in Wootton as set out in the Housing Needs Survey.
• highway works that will improve highway safety; and;
• a range of social and economic benefits and increase spending for local services and facilities.
6.20 In the Site Assessment Pro-Formas June 2021 the subject site is Site ID 371. However, the assessment does not take account of the Officers Report to committee for the application and HSL sent an email to the LPA on 2nd August 2021 setting out our comments which were noted in an email dated 11th August 2021.
6.21 Our position is that the site can be delivered in full in the first five years of the plan period. This is because the land is controlled by HSL, an experienced land promotion company complete with its own housebuilding division. The site is controlled by a willing landowner, and there are no legal or ownership issues that would prevent development. The Council can proceed in the confidence that the site is deliverable, is sustainable overall as confirmed by the application officer’s report and should be allocated on that basis.

Comment

Representation ID: 9905

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

7. Land south of Bromham Road, Biddenham (Site ID 7432)
7.1 The site comprises a field located south of Bromham Road and north of the A6. It is a well contained triangular site with roads and development to the north and an extant consent for development to the south. The western boundary adjoins an existing field.
7.2 Enclosed as Appendix EP2 is a Vision and Delivery Statement. This shows that:
• It is an infill site lying with the urban area boundary to the north and south;
• The site extends to 1.81 hectares. The site is currently undeveloped and is considered suitable for the delivery of around 40 dwellings.
• HSL have undertaken initial survey work and due diligence and have fully considering any constraints and opportunities presented by the site as a whole. An overview of the key technical considerations to-date is also provided, which helps to demonstrate that the site is Available, Suitable, Achievable and can therefore be considered Deliverable;
• Given the site’s context, the site’s attributes and sustainable location make it an ideal logical location for some housing growth on an SME site which the NPPF considers is important. There is an opportunity to provide a sustainable development that meets borough-wide and local housing needs and supports the local economy
7.3 As set out under Policy DS5(S) sites such as this should have been allocated. We now assess how the site was assessed and discounted.
7.4 Page 105 of the SA states:
“The Council has decided that sites adjoining the edge of the urban area in most instances should not be part of the local plan strategy because, in many locations, the gap between the edge of the town and villages surrounding it is very narrow and the strategic expansion of the urban area in recent years has already reduced that separation. The Council’s strategy is not to infill those gaps but to support only two sites adjacent to the urban area, where there are clear benefits associated with delivering the Council’s strategic green infrastructure priorities (Bedford and Milton Keynes Waterway Park and Bedford River Valley Park, including the watersports lake)”
7.5 The omission site is reference 7432. The SA states:
“The location is not consistent with the Council’s preferred strategy. In addition the site is already subject to a development plan allocation (H6) which intended the land to be kept free from development”
7.6 The Site Assessment conclusion on page 878 states:
“The site is outside of the urban area. The location is not consistent with the Council’s preferred strategy. In addition, this site falls within the development area of Policy H6 of the 2002 Local Plan policy for Biddenham Loop which intended the land to be kept free from development.”
7.7 Given how the site has been assessed it is necessary to set out the planning history since the site was identified for development in 1994. This demonstrates that given the consents to the north and south that this site is now suitable as the reasons why it was not shown for development in the revised 2002 Biddenham Loop designation is no longer applicable. Therefore, the constraint to development no longer applies and importantly with regard to page 105 of the SA there would be no reduction in the gap between Biddenham, and Bromham. The extract from the Vision and Delivery Statement encapsulates this in one image.
SEE ATTACHMENT FOR PLAN
7.8 We now assess why we come to that conclusion.

Planning History and Context
7.9 On the Interactive Policies Map for the current local plan, the site is shown under Policy H6 of the 2002 Local Plan and states “Site Name: Biddenham Loop Development Brief - Policy Number: H6”. The inclusion of the site in H6 is used as a reason to discount the site but given that H6 is to be deleted (Page 123 of the Plan), then the site needs to be assessed on the current position.
SEE ATTACHMENT FOR PLAN

7.10 In the extract below, which is from the Biddenham Loop Development Brief in 1994, which we have taken from the 2002 Local Plan, the subject site is shown hatched as residential.
SEE ATTACHMENT FOR PLAN

7.11 The fact that it was identified for residential development demonstrates it suitability as far back as 1994. However, in the Revised Biddenham Loop Development Brief dated 2002 the subject site was shown as part of a wider River Protection Area.
SEE ATTACHMENT FOR PLAN

7.12 Paragraphs 4.12 to 4.14 of the Development Brief then explains the purpose of that designation as follows:
SEE ATTACHMENT FOR ECOLOGY AND LANDSCAPE PARAGRAPH

7.13 In the intervening period, the site no longer has any such ecology or landscape designation on the policies map. In addition, as can be seen from the extract of the Policies Map, with the allocations to the north and south in the 2030 Local Plan and the Upper Great Ouse Rover Valley, then there has been a material change and the site is white land and has no constraint to development.
SEE ATTACHMENT FOR PLAN

7.14 The omission site also lies between Biddenham and Bromham, however the arrows on the policies map for AD42 do not include this site is within the gap. With the development and allocations to the north and south that can only be correct.
7.15 The developer for Policy 18 applied for 249 dwellings which extended the development area shown in the Plan significantly westwards and was won at appeal where a key issue was the gap between Bromham (AD42) and the development of urban open space (AD43).
7.16 Following the refusal of the 249 dwellings scheme the developer submitted an application for 160 dwellings (18/03100/MAO). The committee report states:
“2.17 It was on this basis that the previous application was partly refused: that the proposal for up to 249 dwellings did not adequately respond to ADLP Policies AD42 and AD43. The current application however constrains the extent to which the proposed development would extend westwards and northwards such that the important open visual attributes of the Biddenham – Bromham Gap would not be significantly compromised. The current proposal which is set further off the northern boundary with the A4280 than the previous application proposal and allows a much greater area of existing farmland to be retained west of the site, along with the proposed mitigation planting, would not significantly alter the sense of ‘visual relief’ and openness experienced, and thus the perception of the ‘Gap’, beyond the Deep Spinney roundabout upon leaving Biddenham / Bedford. By constraining the proposed development area to an area comparable to that shown in Figure 6 accompanying Policy 19 in the ELP (accepting that limited weight should be given to the ELP at this current time), the proposal as it stands would not inappropriately intrude into the ‘Gap’ and alter the perception and sense of arrival when approaching Biddenham and Bedford from the west and / or alter the perception of where the urban edge starts. Both physically and visually the existing ‘Gap’ between Biddenham and Bromham would not be unreasonably compressed, a criticism of the previous scheme.”
7.17 The refused 249 scheme referred to in the above quote was then allowed on appeal (Ref 3227767) in October 2019. Policies AD42 and AD43 were assessed in that decision. The Inspector concluded that “given the presence of the Western Bypass and open space between the Local Gap and the appeal site, along with the additional open space to be retained within the appeal site, this is not a case where the proposed development would adjoin the local gap. Consequently, there is no conflict with policy AD42”. He then states:
“22. Therefore, even taking account of the 160 dwelling scheme as a baseline (to which I have given significant weight) the appeal proposal would compromise the purpose of the Gap contrary to the aims of policy AD43 of the ADLP. Taking account of all my reasoning above, I consider that the level of resulting harm would be moderate.”
7.18 The Inspector states that “whilst the benefits of the scheme are considerable, they would not, under a normally weighted balance, outweigh the need to retain the urban open space and gaps as undeveloped”. However, as paragraph 11(d) was engaged the appeal was allowed (see below).
SEE ATTACHMENT FOR PLAN

7.19 For the outline consent (19/01394/MAO) for Policy 23 to the north of the subject site, the officer report states:
“2.19 The local gap identified between Bromham and the
Bedford urban boundary at Biddenham varies between 200 metres at its closest and 1 km. At the position where the site is located the gap between the two settlements is approximately 570 metres wide. Whilst the intervening open land contains some frontage development on Bromham Road, there is no development at depth, except for a single dwelling which is set back and mainly screened from outside of the site. The application site is an undeveloped grassed area, containing no buildings (except 112 Bromham Road), which contributes to the openness of the area and its importance as a visual break between the settlements of Bromham and Biddenham.”
2.20 The previous planning application on this site was refused in principle (reason 1) and due to the character of the development to the rear (reason 2 and 3) and the impact the development would have on the Local Gap. Since that decision the allocation of the land within the emerging local plan 2030 under Policy 23 for housing has been a significant material change in circumstance. This allocation accepts the principle of development at depth on the site and the impact this may have on the landscape and character of the area.
2.21 Given that the emerging policy 23 accepts the principle of housing on the site the general impact of the development on the gap will be a matter for the details of the reserved matters application. At this stage only the access is being considered with all other details being the subject of the further reserved matters applications.”
7.20 The site was approved. Therefore, the planning history demonstrates the fact that the western boundary of the site is in line with the proposed developable area for Phase 2 of the Gold Lane site for the pending application 21/03302, and with the existing and consented (Policy 23) development to the north.
7.21 With respect to the gap between Bromham and Biddenham these consents are a material consideration for the omission site (south of Bromham Road) as it would be a logical infill with no harm. The approved developable area for Policy 18 is in line with its western boundary of the omission site. Therefore, the evidence base has wrongly concluded that the site should be kept free from development. To the contrary it is a most logical site for allocation and early delivery. Conformity with SA and Policy DS5(S) 7.22 In the assessment in the HELAA the site is scored very highly and should have been given further serious consideration in the choice of allocations, particularly as the SA found growth adjoining the urban area performed almost as well as growth within the urban area, was better than new settlement growth, and was better in relation to economic growth. It was also noted that the Council recognises development in the urban area will be more challenging compared with adjacent to the urban area.
7.23 In terms of the Council’s preference for only two sites adjacent to the urban area (based on their benefits associated with the strategic green infrastructure priorities) there is no clear reason why Omission Site 7432 would not deliver any green infrastructure benefits. Indeed, the HELAA assessment recognises that “the site is within or adjoining the green infrastructure opportunity network and is able to enhance the network”.
Conclusion
7.24 To conclude, the site is a logical well contained site that was identified for development as far back as 1994. The gap between Bromham and Biddenham would not be reduced by the allocation of this site. The land south of the A6 (Policy 18) now has consent for 249 dwellings and with the site to the north (Policy 23) also consented, then the development of the subject site will not bring Biddenham any closer to Bromham. With the emerging housing requirement, this site should be allocated.
7.25 This concludes our representations.