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

Support

Representation ID: 8388

Received: 27/09/2021

Respondent: 1 Grosvenor Holdings Ltd

Agent: WSP

HOUSING NEED
The draft Local Plan asks the question:
“How many homes will be needed to be provided across the plan period?”
As outlined in Paragraph 61 of the NPPF, the standard method should be used to calculate future housing requirement and Councils must follow this. Bedford Borough Council (BBC) state a result of the government’s recent revisions to the standard method, the housing requirement for BBC is 1,275 dwellings per year, resulting in a total of 25,500 dwellings for the 20-year period from 2020 to 2040. The Draft Plan indicates that is the current starting point for the Local Plan housing requirement.
When considering existing commitments (planning permissions, allocations from current local plans and an allowance for windfall, which together total 13,000 dwellings), based on the standard method requirement figure of 1,275 dpa, the Draft Plan will need to allocate land to provide a minimum of 12,500 new dwellings.
Further detail is set out in the evidence base document Local Housing Needs Assessment (LHNA), this provides evidence the standard method number for the borough has been altered by recent affordability figures and the LHNA was produced in relation to the previous requirement of 1,305 dpa (a total 26,100 dwellings between 2020 and 2040) and this should therefore be considered as the figure for BBC’s housing requirement per the stand method as defined in the NPPF.
The annual requirement in the adopted Local Plan 2030 is 970 dwellings per year. The 1,305 required dwellings for this new plan represent a substantial increase to the adopted plan and will therefore result in the requirement to allocate additional sites (such as the land off Great Barford High Street) for housing development.

Support

Representation ID: 8389

Received: 27/09/2021

Respondent: 1 Grosvenor Holdings Ltd

Agent: WSP

The Draft Plan outlines four options for the future ‘Growth and Spatial Strategy’ and asks:
“What, in the context of the vision and objectives outlined earlier in the document, is the appropriate spatial strategy for the plan?”
Option 2d (development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes and east parishes, plus one new settlement) represents the optimal and most sustainable option for the borough’s growth and spatial strategy.
The Draft Plan outlines that Option 2d will provide between 12,500 and 13,085 dwellings. This is the one only option that provides over the requirement of the standard method and meets the uplift in housing need outlined in the Council’s LHNA. This therefore the option that complies with the requirement of Paragraphs 60 and 61 of the NPPF.
Paragraph 60 of the NPPF outlines the Government’s objective of significantly boosting the supply of homes. This suggests that Council’s should provide above the minimum housing need identified using the standard method and local housing need assessments (per Paragraph 61 of the NPPF), a view that was taken by an Inspector in a recent appeal1 concerning BBC (in April 2021). This reading of the NPPF suggests that it is clear that the upper limits of housing need should be supported and therefore provides justification for the adoption of Option 2d.
The Government’s objective for significantly boosting the supply of homes (Paragraph 60 of the NPPF) notes that in order to ensure that this can be supported, a sufficient amount and variety of land should come forward where it is needed. This is emphasised by Paragraph 69 which outlines the contribution that small and medium sized sites can make to meeting the housing requirement of the area, noting that 10% of housing delivery can be undertaken on these sites.
Paragraph 69 therefore supports the progression of Option 2d to be selected as the preferred option for the growth and special strategy of the draft Local Plan. This is as Option 2d while it provides much needed dwellings in large scale urban extensions and new settlements (which is supported by Paragraph 73 of the NPPF), it accounts for the parishes of Bedford, which are likely to be able to support smaller and medium sized sites with greater ease. Option 2d is therefore supported by both Paragraphs 69 and 73 of the NPPF as it would enable both small and large sites to come forward for development and significantly boost housing delivery.

Object

Representation ID: 8390

Received: 27/09/2021

Respondent: 1 Grosvenor Holdings Ltd

Agent: WSP

The Draft Plan correctly recognises the importance of delivering development on small sites and notes the NPPF requirement for 10% of housing delivery coming forward on small sites (per Paragraph 69 of the NPPF.
This is positive and supported, as it will increase the diversity of sites that are developed across the Borough and recognises that larger sites are often difficult to develop and deliver houses much slower than smaller sites.
While it is positive that smaller sites are supported by the plan, it not justified to simply use windfall sites to meet the quota outlined in NPPF Paragraph 69. This is as the nature of windfall sites is uncertain and Paragraph 69 explicitly states that development plans should identify small sites to accommodate the 10% target and as such the current policy approach is not in accordance with the NPPF.
The Draft Plan should be amended to allow for smaller sites to be allocated and enable it to be considered sound in relation to Paragraphs 69 of the NPPF. This is due to Paragraph 35, which outlines that plans need to be consistent with national policy and justified if they are to be considered sound.