Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 10004

Received: 29/07/2022

Respondent: Inspired Villages

Inspired Villages supports Policy DM1(S) as it recognises the unviability of C2 uses providing affordable housing. There is a significant amount of floorspace given to the provision of on-site facilities and amenities, which are referred to as non-saleable space, higher construction costs, slower sales rates, staffing, etc. Furthermore, there have been a number of appeals (please refer to para.2.16 of the attached document) that have confirmed the application of affordable housing policy to C2 uses acts as a barrier to development. Inspired Villages therefore supports Policy DM1(S) and find the provisions of this policy to be sound.

Object

Representation ID: 10005

Received: 29/07/2022

Respondent: Inspired Villages

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Supporting paragraph of Policy DM2 seeks mid stage reviews for large scale developments. Large scale developments are considered to be multi-phased developments that are delivered ‘across different stages in an economic cycle’ where mid stage reviews may be appropriate where they are built over a number of years (eg. 10+ yeas) and subject to subsequent permissions. However, the definition provided for large scale developments is not reflective of smaller schemes, for perhaps 100-200 units which are typically single phase schemes. The introduction of mid stage reviews onto these smaller (non strategic) schemes can affect their deliverability and we would caution against their introduction and this should be considered as a Modification to the plan.

Comment

Representation ID: 10006

Received: 29/07/2022

Respondent: Inspired Villages

We support Policy DM3(S) for seeking to providing a suitable mix of tenures for developments of 500 dwellings on more, which will include the provision of C2 uses with affordable housing provision being applicable to the C3 element only.

It is welcomed that Bedford Borough Council are able to acknowledge the increased requirement for specialist housing options for older people; however, the Plan should highlight the additional benefits of extra care housing outlined within the attached representation document particularly the health and wellbeing benefits such as savings to the NHS and social care, as well as reduced mental and physical health problems. Other evidenced benefits of specialist housing for older people include the freeing up of family homes as well as lower traffic generation resulting from such developments. Please refer to paragraphs 3.14 to 4.15 of the attached representation for further details.

Supporting document – Bedford Borough Local Housing Need Assessment – has identified that the majority of population growth within the borough will be within the over 65s demographic (64%). Furthermore, the draft local plan also sets a target for an additional 12,500 homes of which 5,000 have been identified as specialist homes for older persons. it is welcomed that the draft local plan identifies a housing target for specialist older persons housings as the PPG advises that plan-making authorities can “also provide indicative figure figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period” (Paragraph: 006 Reference ID: 63-006-20190626).

The Call for Sites is pending. It is important that specific allocations are made for specialist housing for older people within Policy 60. Allocation should be made for Use Class C2 outside of strategic development areas. Whilst Policy DM3(S) acknowledges for sites providing 500 or more dwellings provide ‘self-contained housing designed to meet the needs of older persons’ it does not specify the variety of tenures available and there is a danger that the land made available within larger development sites set aside for older persons housing risks a generic approach to provision as it does not ensure that all of the different typologies of specialist housing would be provided (e.g. age restricted, retirement housing, extra care (i.e. integrated retirement communities), and care homes) (please refer to paras. 2.13 - .14 of the attached document for the key considerations in the deliverability of one our developments). Finally, I would also draw your attention to the NPPG Paragraph 4 (Reference ID: 63-004-20190626) which states that the future need for specialist accommodation for older people should broken down by tenure and type. Each typology has different requirements in terms of site area, unit numbers, provision of on-site facilities and locational requirements. This must all be taken in to account in drafting policy.