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

Support

Representation ID: 8492

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

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 the increase (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, described as being of national importance by the Government, is delivered.
2.2 The Housing Requirement for Bedford is proposed to be 25,500 dwellings between 2020 and 2040, equating to 1,275 dwellings per annum, as established through the standard method. The Council consider that 13,000 dwellings will be delivered through existing commitments, derived from planning permissions, current allocations and a windfall allowance. As such 12,500 dwellings need to be planned for in the emerging Plan to ensure Local Housing Need can be met.
2.3 The Planning Practice Guidance (PPG) is clear that when establishing a housing requirement “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.” [our emphasis] (Paragraph: 010 Reference ID: 2a-010-20201216). Examples of scenarios which may justify an increase of housing requirement include growth strategies, the delivery 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. It is also important to note that Local Housing Need is, outside of the 20 largest towns and cities, a policy-off figure, as such delivering base Local Housing Need cannot be said to be delivering policy-on objectives relating to economic growth for example.
2.5 Within the emerging draft Plan 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 paragraph 1.5 of the Development Strategy Topic Paper (June 2021), despite acknowledging this figure
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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 – ‘Creating a Vision for the Oxford-Cambridge Arc’ – 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, is entirely sensible and is 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. Even if 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 emerging 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.
2.7 It will be an unacceptable position for this emerging Plan to be subject to an early review clause, as is the case in the current Local Plan. Such an approach would merely serve to frustrate and slow much needed development.
2.8 Planning only for the baseline requirement of Local Housing Need for all Arc Authorities would result in a significant shortfall against the agreed housing target of one million dwellings up to 2050 which are needed to support the economic goals of the Arc. The Standard Method, for all authorities, totals just over 20,000 dwellings per annum. To meet the one million dwelling target across the Arc, would take around 47 years if only 20,000 homes per annum are delivered; 18 years beyond the 2050 target. Using base Local Housing Need, the Arch Authorities will deliver only 63,500 dwellings up to 2050; 65% of the housing required. It is clear therefore that planning to meet the base Local Housing Need is inappropriate and an uplift is required likely in excess of 20%. The later Authorities start to uplift their housing requirement, the harder it will be to satisfy, as fewer years will remain to deliver the need. It is therefore considered that the housing requirement should be uplifted now in accordance with the emerging Spatial Framework, as is being explored by other authorities, including West Northamptonshire which has set out that a 40% increase in housing requirement may be necessary to fulfil its housing obligations as an

Arc authority.
2.9 The proposal to utilise a stepped trajectory, referenced at paragraph 3.5 of the draft Plan, is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is primarily due to the approach to reduce the adopted Plan period, to a functional period up to 2030, despite the concerns of the development industry at the time. It is to us entirely inappropriate that these reported difficulties can be used as justification to delay current housing needs to later in the Plan period. This approach is particularly considered problematic in that, as detailed previously, housing needs will increase further; this, combined with stepping the trajectory to deliver increased numbers later in the Plan period will only further compound delivery. 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, including land east of Newton Lane, Turvey, 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.

Support

Representation ID: 8494

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.10 Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.
2.11 In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.
2.12 The issue with the other options (rail-based, east-west rail northern station and new settlement) is that they place 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 limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain
a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
2.13 Dispersed growth should form part of every spatial option proposed, 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 and shops and the 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 (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of 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 mechanism of future delivery, caution should be applied to overreliance on the delivery 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. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.
Site Allocations and Call for Sites
2.16 The Council have previously evidenced that settlements such as Sharnbrook can deliver up to 500 dwellings in the period up to 2030. The emerging Neighbourhood Plan seeks to allocate 500 dwellings beyond the settlement of Sharnbrook, at Coffle End, another settlement within the Local Plan settlement hierarchy. As such it is considered that no growth has been directed to Sharnbrook itself over the adopted Plan period to 2030. Furthermore, the emerging Local Plan looks beyond 2030 to 2040, and thus commensurate additional further growth in the sustainable rural settlements must be delivered during this extended time period., The 500 dwellings allocated at Coffle End in the emerging Neighbourhood Plan will not be sufficient to meet the housing needs in Sharnbrook up to 2030, or 2040. It is considered that sustainable growth in settlements such as Sharnbrook, up to 2040, should be in the region of a minimum 100 dwellings (additional dwellings beyond the 500 allocated in emerging Neighbourhood Plan). This is consistent with the Councils previous evidence base, current housing targets, and commensurate to their sustainability and spatial role. As previously set out, we would object to any attempt to stifle appropriate rural growth.
2.17 In that regard, we consider the emerging Local Plan must make allocations in the Rural Service Centres to ensure a suitable distribution of deliverable development sites up to 2040. Within Sharnbrook it is clear through both the evidence supporting the Neighbourhood Plan and the previous assessments supporting the adopted Local Plan (whereby the Council’s 2017 Local Plan consultation paper sought to identify preferred sites for allocation, which included land at Kennell Hill), that the most suitable and deliverable site beyond those allocated in the Neighbourhood Plan is land at Kennell Hill, Sharnbrook. A range of evidence documents have been produced by Anwyl Land which demonstrate the deliverability of the site.
2.18 The Council have assessed the Kennell Hill, Sharnbrook site under ID reference 3231. We have a number of concerns with the scoring of this site. We also have a number of comments in respect of the emerging Neighbourhood Plan allocation, which whilst being allocated through a separate process is considered as part of this SHLAA assessment and will be a matter for the Council to consider. These are discussed in turn, followed by more general comments in respect of the settlement generally.

Support

Representation ID: 8496

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.33 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding is not supported and is not consistent with the Council’s own evidence and is not consistent with how 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.
2.34 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 is sufficient units being delivered.
2.35 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 estates. Our experience is that for the most part that they are instead looking for more bespoke rural opportunities.
2.36 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.
2.37 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.

2.38 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.
2.39 The Council should be guided by its evidence and remove this policy requirement. Without such alteration this policy is considered unsound as it is not justified, effective or consistent with national policy.

Support

Representation ID: 8498

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.40 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.