Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10416

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The current Core Strategy identifies, Great Barford as containing 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area'. The strategy alighted upon for the Regulation 19 plan however, whilst continuing to identify the role of Great Barford as a Key Service Centre, does not seek to identify a single additional home to the village, beyond that already committed through the current Core Strategy and identified via the Neighbourhood Plan.

Objection is raised to the overarching spatial strategy's reliance on a limited number of large sites to deliver the new homes required for the Borough. This is at the total exclusion of growth within sustainable settlements such as Great Barford, which are capable of accommodating additional growth on smaller sites well related to the urban fabric. These would be capable of early delivery, thereby avoiding the need for a stepped trajectory, and would meet need both when it arises, and within sustainable locations.

Objection is raised to the Local Plan Policies DS2(S), DS3(S) and DS5(S), on the grounds that these key policies embed an unsustainable growth strategy for the Borough, which fails to have regard to the evidence base, and which fails to follow through on the recognition of the settlement hierarchy, notably, larger villages such as Great Barford, which are identified as Key Service Centres and for which no new allocation is made for the plan period. In this case, the provision of a stepped trajectory, thereby denying the requirements of those in housing need today, is considered to be an unnecessary deferral of delivery. It also requires a significant uptick on historic delivery rates, over rates achieved in recent years. A strategy which draws on some smaller/medium sized sites, capable of faster delivery, would be more sustainable as p art of an overall balance which might still favour longer term delivery through large sites.

With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as Great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy should reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.

For the above reasons the identified Policies DS2(S), DS3(S) and DS5(S), are considered unsound as they are neither Positively Prepared, Justified, Effective, nor consistent with National Policy .

Object

Representation ID: 10417

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The current Core Strategy identifies, Great Barford as containing 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area'. The strategy alighted upon for the Regulation 19 plan however, whilst continuing to identify the role of Great Barford as a Key Service Centre, does not seek to identify a single additional home to the village, beyond that already committed through the current Core Strategy and identified via the Neighbourhood Plan.

Objection is raised to the overarching spatial strategy's reliance on a limited number of large sites to deliver the new homes required for the Borough. This is at the total exclusion of growth within sustainable settlements such as Great Barford, which are capable of accommodating additional growth on smaller sites well related to the urban fabric. These would be capable of early delivery, thereby avoiding the need for a stepped trajectory, and would meet need both when it arises, and within sustainable locations.

Objection is raised to the Local Plan Policies DS2(S), DS3(S) and DS5(S), on the grounds that these key policies embed an unsustainable growth strategy for the Borough, which fails to have regard to the evidence base, and which fails to follow through on the recognition of the settlement hierarchy, notably, larger villages such as Great Barford, which are identified as Key Service Centres and for which no new allocation is made for the plan period. In this case, the provision of a stepped trajectory, thereby denying the requirements of those in housing need today, is considered to be an unnecessary deferral of delivery. It also requires a significant uptick on historic delivery rates, over rates achieved in recent years. A strategy which draws on some smaller/medium sized sites, capable of faster delivery, would be more sustainable as p art of an overall balance which might still favour longer term delivery through large sites.
Lone Star have concerns regarding the reliance within the Regulation 19 Local Plan on use of a stepped trajectory, as set out in Policy DS3(S). The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.

The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6
- 10. The National Planning Policy Framework ("NPPF") does not support the deferral of meeting the known housing requirement to beyond year 10. Planning Practice Guidance (68 - 0 21) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.

The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.

To achieve this objective of national policy guidance, to meet the housing requirement with positive site allocations in years 1 to 10 of the plan or at least broad areas of growth from beyond year 5, the plan should balance away from such a heavy reliance on freestanding large new settlements. Currently, the Reg 19 plan speculates that the step might shift from 970 dw/yr up to 2030, with 1,5700 dw/yr beyond 2030, i.e. deferring 17,000 of the Plan's 27,10 0 dw requirement to later in the plan period.

The Council are therefore invited to review the trajectory of delivery for their Regulation 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.

With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as Great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy should reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.

For the above reasons the identified Policies DS2(S), DS3(S) and DS5(S), are considered unsound as they are neither Positively Prepared, Justified, Effective, nor consistent with National Policy .

Object

Representation ID: 10418

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The current Core Strategy identifies, Great Barford as containing 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area'. The strategy alighted upon for the Regulation 19 plan however, whilst continuing to identify the role of Great Barford as a Key Service Centre, does not seek to identify a single additional home to the village, beyond that already committed through the current Core Strategy and identified via the Neighbourhood Plan.

Objection is raised to the overarching spatial strategy's reliance on a limited number of large sites to deliver the new homes required for the Borough. This is at the total exclusion of growth within sustainable settlements such as Great Barford, which are capable of accommodating additional growth on smaller sites well related to the urban fabric. These would be capable of early delivery, thereby avoiding the need for a stepped trajectory, and would meet need both when it arises, and within sustainable locations.

Objection is raised to the Local Plan Policies DS2(S), DS3(S) and DS5(S), on the grounds that these key policies embed an unsustainable growth strategy for the Borough, which fails to have regard to the evidence base, and which fails to follow through on the recognition of the settlement hierarchy, notably, larger villages such as Great Barford, which are identified as Key Service Centres and for which no new allocation is made for the plan period. In this case, the provision of a stepped trajectory, thereby denying the requirements of those in housing need today, is considered to be an unnecessary deferral of delivery. It also requires a significant uptick on historic delivery rates, over rates achieved in recent years. A strategy which draws on some smaller/medium sized sites, capable of faster delivery, would be more sustainable as p art of an overall balance which might still favour longer term delivery through large sites.

Lone Star have concerns regarding the reliance within the Regulation 19 Local Plan on use of a stepped trajectory, as set out in Policy DS3(S). The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.

The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6
- 10. The National Planning Policy Framework ("NPPF") does not support the deferral of meeting the known housing requirement to beyond year 10. Planning Practice Guidance (68 - 0 21) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.

The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.

To achieve this objective of national policy guidance, to meet the housing requirement with positive site allocations in years 1 to 10 of the plan or at least broad areas of growth from beyond year 5, the plan should balance away from such a heavy reliance on freestanding large new settlements. Currently, the Reg 19 plan speculates that the step might shift from 970 dw/yr up to 2030, with 1,5700 dw/yr beyond 2030, i.e. deferring 17,000 of the Plan's 27,10 0 dw requirement to later in the plan period.

The Council are therefore invited to review the trajectory of delivery for their Regulation 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.

With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as Great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy should reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.

For the above reasons the identified Policies DS2(S), DS3(S) and DS5(S), are considered unsound as they are neither Positively Prepared, Justified, Effective, nor consistent with National Policy .