Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 9573

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policies DS2(S) and DS5(S) sets out the proposed distribution of growth in the Borough.
L&Q broadly support the growth strategy, which seeks to focus new residential development within the main Bedford urban areas, and at strategic urban extension locations where new development can contribute to the objectives of the Oxford – Cambridge Arc, and be delivered alongside appropriate infrastructure.
However, we would highlight the viability challenges associated with brownfield, urban town centre development, for example addressing ground contamination and utilities. For residential development, the need to optimise housing delivery in these locations is essential to making schemes viable and deliverable and flexibility around key, competing policy requirements is required. Due to the national and borough housing need, we would encourage the Council to support proposals for housing delivery outside of the identified areas for strategic growth, on a site by site basis, nothing the contribution that smaller, infill site developments can make.
As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In that context, it supports the intention to deliver sustainable future urban extensions within the South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic place making framework for the South of Bedford policy area will be adopted as a Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022) indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good access to employment centres, it located in the Oxford – Cambridge Arc growth area, it benefits from existing infrastructure, and has the potential to deliver additional new infrastructure where required.

Comment

Representation ID: 9574

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policies DS2(S) and DS5(S) sets out the proposed distribution of growth in the Borough.
L&Q broadly support the growth strategy, which seeks to focus new residential development within the main Bedford urban areas, and at strategic urban extension locations where new development can contribute to the objectives of the Oxford – Cambridge Arc, and be delivered alongside appropriate infrastructure.
However, we would highlight the viability challenges associated with brownfield, urban town centre development, for example addressing ground contamination and utilities. For residential development, the need to optimise housing delivery in these locations is essential to making schemes viable and deliverable and flexibility around key, competing policy requirements is required. Due to the national and borough housing need, we would encourage the Council to support proposals for housing delivery outside of the identified areas for strategic growth, on a site by site basis, nothing the contribution that smaller, infill site developments can make.
As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In that context, it supports the intention to deliver sustainable future urban extensions within the South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic place making framework for the South of Bedford policy area will be adopted as a Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022) indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good access to employment centres, it located in the Oxford – Cambridge Arc growth area, it benefits from existing infrastructure, and has the potential to deliver additional new infrastructure where required.

Comment

Representation ID: 9575

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM1(S) sets out the Council’s approach to affordable housing. We have a series of comments.
Firstly, the draft policy states that sites of 10 or more residential units, or 0.5 hectares or more will provide 30% affordable housing with 75% of the dwellings as social or affordable rented properties, and the remainder (25%) as First Homes at a 50% discount.
L&Q understands that the National Planning Practice Guidance requires new development to provide 25% of new dwellings as First Homes. However, we do query the proposed level of discount identified. Amongst other criteria, the NPPG requires that First Homes must be
discounted by a minimum of 30% against the market value, and that after the discount has been applied, the first sale must be at a price no higher than £250,000 (in this location). The Guidance goes on to state that a 40% or 50% discount can be set by a local authority where
they can demonstrate a need for this. L&Q, as a Registered Provider of affordable housing, has concerns that the Council’s proposed approach will affect development viability and the subsequent impact on the delivery of more genuinely affordable tenures such as social/affordable rent. Our concerns extend further in this case given that the discount offered is at 50%. Where viability is impacted, this could reduce overall housing supply across all tenures.
Draft Policy DM1(S) goes on to state that ‘Affordable rents will be 80% of open market rents but a lower percentage should be set where this would preclude access to housing benefit.’
L&Q support this policy position as we understand the importance of genuinely affordable rents for residents accessing housing benefit.
It also states that ‘where shared ownership is offered it will be on the basis of a range of initial share purchases from 10 - 80%.’ Firstly, it is highlighted that under the Council’s general affordable homes approach (75% social/affordable rent, and 50% First Homes), there would be no scope for shared ownership products. Secondly, the scale of 10 – 80% represents a
significant range, and we would query whether a model with an 80% initial share would represent a genuinely affordable housing offer. We would also highlight the important and effective role that intermediate tenures such as Shared Ownership play in opening up routes
to home ownership for those with affordability restrictions. This exacerbates our concerns over the absence of products like Shared Ownership and the promotion of First Homes.
Draft Policy DM1(S) goes on to state that on sites providing a mix of affordable and market homes, the Council will expect the affordable housing to be integrated within the market housing and affordable housing clusters should not exceed 15 dwellings and should not be readily distinguishable from market housing. Whilst L&Q promote high quality, tenure neutral
design across all its developments, for flatted developments we require social/affordable
rented to be provided within a dedicated core which enables us to deliver affordable service charges and provide effective housing management for those residents.

Comment

Representation ID: 9576

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM2 (Review Mechanisms) sets out the proposed approach to affordable housing
review mechanisms. Whilst we do not object in principle to the provision of review mechanisms
to secure an uplift in affordable housing provision, we feel it is important that viability review
timeframes are determined on a scheme by scheme basis, given that project timescales can
vary significantly between developments. For instance, five years after the date of the original
viability assessment, does not feel like an appropriate measure given the time it can take for
planning permission to be granted and then to mobilise the for start on site - a project could
still be at a very early stage at this point in time.at this point.

Comment

Representation ID: 9577

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM3(S) (Housing mix) requires new housing developments to provide a mix of
dwelling size and type to meet the identified needs of the community including families with
children, older people, people wishing to build their own homes and people with disabilities
and special needs in accordance with the Council’s current Local Housing
Needs Assessment. Clearly each scheme should be considered on its own merits and it is
unrealistic that all of these unit types could be applied to all development proposals. Whilst it
is recognised that the subsequent paragraphs provide additional detail, it would be helpful to
add ‘as appropriate’ to the paragraph, as this could be considered ambiguous as currently
worded. Referring back to our earlier comments about optimising housing delivery to meet
housing need and the inherent design constraints associated with urban, brownfield
redevelopment, flexibility on housing mix policies is important.
Draft Policy DM3(S) goes on to state that ‘All developments of 500 dwellings or more in
suitable locations, will be required to include self-contained housing designed to meet the
needs of older persons, and / or supported living accommodation in accordance with the
Council’s most up to date statement of need on older person’s accommodation.’
L&Q has an extra care and support arm, L&Q Living, which manages homes for our most
vulnerable residents. In our experience, extra care and sheltered accommodation is typically
brought forward as independent developments i.e. not part of a wider scheme with private,
intermediate and other affordable tenures. Whilst we do not object in principle to Policy
DM3(S) we would ask for flexibility in discussions around this requirement to ensure that extra
care and sheltered accommodation is being delivered in the right locations and for the right
end users. Also, we feel it is important that the Council’s preferred market and affordable unit
mix (and older persons, and / or supported living accommodation as a proportion of overall
housing need) need for is clearly set out. In L&Q’s view the Bedford Borough Local Housing
Needs Assessment (April 2022 Update) does not present this information in a clear way.
Draft Policy DM3(S) goes on to state ‘All developments of 100 dwellings or more in suitable
locations, will be required to include specialist housing designed to meet the needs of those
with a learning disability or mental health need in accordance with the Council’s most up to
date statement of need.’
Whilst there is no objection to the aspirations of this policy, it is important that the Council’s
requirement for specialist housing need (as a proportion of overall housing) for is clearly set
out. In L&Q’s view the Bedford Borough Local Housing Needs Assessment (April 2022
Update) does not present this information in a clear way. We would also query what constitutes
a design that meets the needs of those with learning disability or mental health need and would
welcome some guidance on this. As we have mentioned earlier in this letter, flexibility is
required around competing design and space demands to ensure schemes are deliverable
and viable.

Comment

Representation ID: 9578

Received: 20/07/2022

Respondent: L&Q Estates Limited

As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In
that context, it supports the intention to deliver sustainable future urban extensions within the
South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of
Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic
place making framework for the South of Bedford policy area will be adopted as a
Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022)
indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East
of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good
access to employment centres, it located in the Oxford – Cambridge Arc growth area, it
benefits from existing infrastructure, and has the potential to deliver additional new
infrastructure where required.

Comment

Representation ID: 9579

Received: 20/07/2022

Respondent: L&Q Estates Limited

As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In
that context, it supports the intention to deliver sustainable future urban extensions within the
South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of
Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic
place making framework for the South of Bedford policy area will be adopted as a
Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022)
indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East
of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good
access to employment centres, it located in the Oxford – Cambridge Arc growth area, it
benefits from existing infrastructure, and has the potential to deliver additional new
infrastructure where required.