Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 6569

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Housing Requirement
2.1 The Council propose to utilise base Local Housing Need as established through the Standard
Methodology as the adopted housing requirement. The Council conclude that this uplift (from the
existing housing requirement) will assist in meeting the wider aims of the Oxford-Cambridge Arc, which
advocates for significant growth in housing to ensure economic growth in the region, which is described
as being of national importance by the Government, is not fettered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, 1,275
dwellings per annum as established through the standard method. The Council consider having regard
for existing commitments, derived from planning permissions, current allocations and a windfall
allowance which all equate to 13,000 dwellings, meaning the Council need to positively allocate 12,500
dwellings to ensure Local Housing Need can be met.
2.3 The PPG 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. (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.
2.4 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing
requirement from local housing need are necessary should be undertaken prior to and independently
from any consideration of the ability of an area to meet that need.
2.5 Within the draft Plan document and supporting documents, the Council do not substantively consider
any merits for uplifting Local Housing Need, beyond a brief reference to the Oxford Cambridge Arc at 1.5
of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure is a minimum.
The Council set out that it is not possible to positively plan for the increased requirements of the Arc due
to the Arc Spatial Framework having been delayed 2 years. We do not consider this to be sufficient reason to not positively Plan for this in the short term. There is currently an initial consultation on the Arc
Spatial Framework - until 12th October 2021 with a
draft Spatial Framework due to be published for consultation in autumn 2022, followed by the
implementation of a final framework.
2.6 Uplifting on the basis of the Oxford Cambridge Arc, something which is entirely sensible and in
accordance with the PPG and the Joint Declaration, signed by Bedford Borough Council. As a constituent
member of the Arc, Bedford should be involved in active engagement with the emerging Spatial
Framework and as such should be in a position to at the very least estimate the likely level of any uplift
forthcoming on the basis of ongoing discussions. The consultation document does not yet indicate a
specific locations and levels for growth, however great emphasis is placed on the concern about the
economy and environment. Place-making will be at the heart of the Arc utilising the opportunity for it to
a world leader in sustainable place-making and community living
2.7 Even if in due course there is some debate as to the level of update required, the Council could choose a
conservative uplift in the interim period. For example, if the level of uplift in the draft document is
proposed to be 30%, the Council could seek to positively apply an uplift of 20% as part of this Plan. This
is positive, in keeping with the Framework and entirely sensible. A more positive approach at this stage
will enable the Council to better Plan strategically for future uplifts, through for example through the
delivery of strategic sites.
2.8 It will be an unacceptable position for this Plan to again by caveated by an early review clause, as was
the Case in the current Local Plan. This will merely serve to frustrate and slow much needed
development.
2.9 It is evident running base Local Housing Need of all Arc Authorities would result in a significant shortfall
against the agreed housing target of a million dwellings up to 2050 which are needed to support the
economic goals of the Arc. In total, the result of the Standard Method for all authorities is just over 20,000
dwellings per annum. This means it will take around 47 years to reach the housing target, if all authorities
simply make provision for base Local Housing Need, 18 years beyond the 2050 target. Using base Local
Housing Need, the area will deliver only circa 63,500 dwellings up to 2050, only around 65% of the
housing required. It is therefore demonstrable at this stage that base Local Housing Need is
inappropriate, and an uplift is required likely in excess of 20%. The later Authorities begin to uplift their
housing requirement, the harder it will be to satisfy, as fewer years will remain. We therefore consider that the Council should seek to uplift the housing requirement now in accordance with the emerging
Spatial Framework, as is being proposed by other authorities.

Object

Representation ID: 6570

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

2.10 In respect of the draft Plan's proposal to potentially utilise a stepped trajectory, referenced at 3.5 of the
draft Plan, this is something which is not supported and not considered sound. Whilst the Council point
to difficulties in achieving the uplift against the current housing requirement, this is partially due to the Council's approach with regard to the previous Plan and adopting a Local Plan with a functional period up to 2030 only, despite the concerns of a number of development stakeholders. It is to us entirely
inappropriate that this can be used to fetter current housing needs to later in the Plan period. This
approach is particularly considered problematic in that it is anticipated that housing needs will increase
through the Spatial Hierarchy, thus further compounding delivery requirements later in the Plan period.
We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of
housing cannot be delivered in the short term and we are aware of a number of sites which are available and can make an immediate contribution to the Council's housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised and in reality, it would likely damage the authority in
later years by resulting in an unacceptable annual requirement.

Object

Representation ID: 6572

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Growth Strategy Options
2.11 In respect of the proposed growth strategy options, at this stage we consider the distribution of housing
should be displayed as a percentage, that way it can more quickly respond to changes in housing
requirement for example, whilst maintaining the spatial distribution of housing.
2.12 In respect of the proposed options, we consider it almost inevitable that the spatially optimal solution is
likely to be a hybrid of a number of the referenced options. Our favoured approach would be an approach
which seeks to continue delivery in the urban areas, deliver higher growth on key transport corridors,
particularly the A421, but retains an apportionment of growth to be disbursed to the rural area. The issue
with the other options is that they place too significant an emphasis on delivery on limited areas. Such
an approach reduces the ability of the market to function most efficiently, as the variety and competition
will be reduced. This reduces the ability for small and medium housebuilders to enter the market and
reduces the options for home purchasers. This will become particularly apparent if a higher housing
requirement is deemed to be appropriate, placing further emphasis on a more limited pool of
settlements. Dispersed growth as well as assisting delivery, encouraging a wider range of housebuilders
into the market delivering concurrently, also has the benefit of supporting rural communities remain vibrant and ensuring a healthy demographic composition, preventing issues such as village ageing.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) in our opinion should
form part of every spatial option, albeit the level to be delivered could of course differ option to option.
We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established
at this point the significant harm such an approach has caused in recent years nationally, as reflected in
matters such as declining public transport routes, closure of village pubs, closure of shops and the
general decline in vitality of village life generally where development has been withheld. Whilst the current
plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result
in a 10-year period with no proposed growth which would be unacceptable and as such some provision
must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including
recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing
prevalence of home working and the greening of private vehicles through developments in electric
vehicles, which by the end of the Plan Period are likely to be highly prevalent, with new petrol and diesel
car sales ending in 2030. Post lockdown there is likely to be a continued demand for semi-rural
opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a facet of future delivery,
we would urge caution be applied if the Council are to rely heavily on delivery arising from new
settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites
are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery
prior to the first dwellings being delivered. Our preferred approach in this scenario is to positively allocate
such sites above and beyond the sites needed to meet housing needs. If work is underway and delivery
has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which
should provide the confidence needed to the market to commit to the works and evidence necessary to
obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn't come forward at all. We would not object if Strategic Sites were used to facilitate an increase
in housing requirement, to provide delivery later in the Plan period. This should not be delivered through
a stepped trajectory, with sufficient land needing to be allocated to deliver Local Housing Need in full
through the Plan period.
2.16 The above approach is potentially beneficial in that it means the Council can retain an element of control,
meaning they can ensure the new settlement/s comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery.
If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence
and appropriate planning consents, then the Council can begin to rely on delivery to meet base Local
Housing Need. Given the likely lead in times, it is considered unlikely any development will be forthcoming
until the latter end of the Plan period. As such if a higher housing requirement is assessed as being
necessary, additional smaller sites will need to be identified in the early years of the Plan. This approach
however could provide supply in the long term and an important avenue for future delivery, particularly
towards 2050.

Object

Representation ID: 6573

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Self-build and custom housebuilding
2.32 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding
with how the Council has interpreted other evidence and how such evidence has informed other policies
within the Plan. The Council has published evidence on the topic in the document the Bedford Borough
Local Housing Needs Assessment Self-build and Custom Housebuilding (April 2021). This document
concludes that the desires of self-builders is to build large, expensive properties and that currently
sufficient single dwelling permissions adequately caters for this need. This accords with our
understanding of self-build, wherein people are seeking bespoke and unique opportunities, not simply
adjacent to a modern housing development.
2.33 Despite this, and for no justified reason, the Council have opted to seek to promote a policy which
requires serviced plots to be delivered on the majority of new housing sites. This approach is not
effective, consistent with evidence and as such is not supported nor considered sound. It is not clear
what the housing target is for self or custom build, and how this has informed the policy, particularly
having regard for the conclusions of the evidence document which demonstrates that there are
sufficient units being delivered.
2.34 It is well established that such criteria are difficult to deliver on modern housing developments and do
not serve to provide additional units. In reality, such requirements may impede development
unnecessarily, adding to developer burden with little merit. Such proposals can create enclaves within
or adjacent to housing schemes, with designs which may be entirely at odds with the aesthetic of the
rest of the scheme, which will have been specifically designed as a collective whole. In our experience,
self-builders generally do not want to buy serviced plots within or adjacent to a modern housing estate.
Our experience is that for the most part that they are instead looking for more bespoke rural
opportunities.
2.35 We are yet to see evidence that this method of delivery has been successful. Furthermore, just because
individuals are registered on the self-build register it does not mean that they will all build their own
property, even if suitable land was available. The reality is the difficulty and skills required will mean only
a small percentage of those on the register will ever develop a self-build property. It is also important to
note that individuals can be on multiple self-build registers, even with a local connection test, which
inflates the figures across a number of areas. Unless demand for plots is means tested, with expressions
of interest supported by evidence of finances to build such a house, to simply just deliver self-build plots on strategic sites is an arbitrary approach which lacks nuance and will harm more justified housing
delivery.
2.36 This policy requirement will serve to frustrate and slow housing delivery, given special consideration
would need to be given to the location of the plots and how they can be accessed safely and
independently from the typical development parcels. The delivery of plots following unsuccessful
marketing is also more complex than suggested within the policy. The Policy assumes such plots could
simply just be built out by the developer; the nature of the plots may not however lend themselves to
being built by the developer and as such could leave undeveloped plots for significant period of time.
Such requirements will also deter developers, given the increased complexity and lack of certainty of
outcomes. Custom build may not be in the business model of some housebuilders, which may preclude
them from bidding for sites if such a requirement is retained. Self and Custom build is a market choice
and should be led by the free market, it is not and should not be treated as a need to be satisfied in the
same manner as affordable housing. If there is sufficient demand for such units, and people are willing
to pay a premium, then it will be adopted by more housebuilders.
2.37 The Council should instead seek to ensure the continuation of a positive policy environment where
suitable self-build schemes, either of individual units or larger schemes or specific schemes providing
serviced plots will be treated favourably. This encourages delivery in line with the Council's statutory duties, without compromising sites which make up a vital facet of the Council's overall proposed housing supply. It will also more likely better serve the self-build market by enabling development in line with the
wishes of perspective self-builders. Having regard for the evidence, this policy is not sound, as it is not
effective nor justified.
2.38 It is noted that Council's evidence as suggested that sufficient small-scale windfall housing sites are
expected to come forward to negate the need for a specific policy or allocations to guarantee the 10%
small sites requirement. This is a very similar position to self-build/custom-build, where the evidence
suggests there is not a need for a policy intervention and as such none is suggested. This is entirely at
odds with the self/custom build policy, which again is clearly not necessary, but the approach adopted
is entirely different. The Council should be guided by its evidence and remove this policy requirement.

Object

Representation ID: 6574

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Residential space standards
2.39 The requirement for all new dwellings to meet prescribed national space standards as a minimum, as
proposed through Policy DQ1 Residential space standards is not supported and has not been justified.
The justification provided is that the standards have been mandated for homes delivered through
permitted development rights. This was however in response to a specific issue identified with homes
delivered through PD rights, with many being delivered in former office blocks or other buildings which
resulted in smaller dwellings. This does not justify the approach adopted by the Council in respect of
new build units. If the Council is to introduce this policy, it must have evidence to point to a specific issue
existing in Bedford Borough and the issues this is causing and hence why a policy intervention is
necessary. Without this the Council is not justified in relation to this policy. Moreover, the Council should
be aware of delivering such requirements and the impacts on sale prices, as larger dwellings will attract
higher prices, having a disproportionate impact on larger families who do not qualify for social housing,
but require a larger property.