Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9655

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DM3(S) is supported with reservations regarding the soundness of the policy. It is noted that the policy varies only minimally from the existing Local Plan Policy 59S Housing Mix.

The proposed development upon the Land at Bedford Heights (HOU10) is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Verve Developments Ltd acquired the wider Bedford Heights site in 2014. Verve Developments Ltd have a long-standing objective of providing housing for those with specific housing needs as part of a longer-term legacy. A partnership has been formed with IMPAKT Housing and Support to provide a small-scale development aimed at providing semi-independent housing with arm’s length support, along with some on-site communal facilities for those with housing needs and to tie this with opportunities for training and employment.

Draft Policy DM3(S) references the current Local Housing Needs Assessment amongst other current assessments of specific housing need and makes reference to evidence in respect of the needs of other specialist groups. Flexibility should be incorporated into the draft policy to allow for a more limited provision of size and type of affordable housing when the specific need can be evidenced. For this reason, the draft policy is not positively prepared and not effective.
As set out within the draft policy DM3(S), the Council anticipates all of its housing needs of different groups being met through all new housing development. In practice this will necessitate substantial elements of the needs of different groups being provided as a proportion of large-scale strategic developments outside of the urban area and outside of existing settlements (including proposed new settlements) where delivery is deferred until later in the plan period. The proposed development for the site is of 36, 1-bed affordable units and will address a substantial current need as outlined below.

The Council’s Interim Housing Monitoring Report (2020-21) shows that a net total of 192 affordable housing units have been completed during this time. These figures are not broken down into dwelling size and bedroom numbers.

Proposed development schemes seeking to meet an identified specialist housing need should be supported in principle. Where the mix of size and type is meeting a specific and evidenced need this should be supported and the policy should reflect this to allow the plan to positively respond to future proposals. As currently drafted it is not positively prepared in this regard.

The inclusion of accessible and adaptable dwellings provision through meeting M4(2) and (3) requirements drafted in Policy DM3(S) is supported. The proposed development will look to meet these requirements.

The proposed development would contribute towards the Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update, which in Figure 9 sets out a total affordable housing requirement for 1 bedroom affordable dwellings of 1,218.

The Council’s Housing Strategy 2021-2026 refers to identifying other vulnerable groups of people’s housing needs (8.3.2) and refers to facilitating opportunities to deliver supported housing needs although it does not identify a specific figure for the needs of these groups. As such, this is an important component of housing need not acknowledged in the first paragraph of Policy DM3(S) and a corresponding reference should be provided in the supporting text of the policy.

New specialist housing is referred to in the Council’s Local Housing Needs Assessment which includes supported housing. The glossary to this document refers to the Homes England identification of broad client groups for this type of housing - Capital Funding Guide – 3. Specialist Homes – Guidance – GOV.UK (www.gov.uk) Section 2.3.4 of this document is repeated below : -
1. Purpose-designed supported housing for disabled and vulnerable people
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features. There must be support services provided by the landlord or another organisation. As a minimum, a building or scheme must have the following:
Facilities: The scheme or main building must have basic facilities of a laundry for residents or washing machines in living units provided by the landlord and must also have a communal lounge
Design features: The entrance area into the building, communal areas and some living units must be designed to wheelchair user standards
2. Purpose-designed housing for disabled and vulnerable people with access to support
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features, as per definition 1 above, but without the requirement for support services to be provided on site. Tenants must instead have access to support and a process be in place to assist in accessing and/or signposting them to the support services that they need.
The proposed development would assist in meeting the needs of vulnerable people who have and are on a journey to independent living with arm’s length support provided, which is a well understood component of housing need that meets specific design requirements.

There is, however, no need figure set out within the LHNA document or within the draft Policy and this presents a clear limitation on how proposals to meet this important component of housing need should be assessed. In practice, as demonstrated by our client’s proposals and the expected profile of future occupiers, the majority of requirements for such accommodation are for one-bed properties.

Draft Policy DM3(S) does not make specific reference or recognise that development may come forward, as proposed at Bedford Heights, that require specific design features and access to support services in response to these needs and should accordingly be assessed favourably in-line with meeting the housing needs of different groups.

Comment

Representation ID: 9660

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy HOU10 is supported with reservations regarding the soundness of the policy.

The proposed development at the Land at Bedford Heights is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Verve Developments Ltd acquired the wider Bedford Heights site in 2014. Verve Developments Ltd have a long-standing objective of providing housing for those with specific housing needs as part of a longer-term legacy. A partnership has been formed with IMPAKT Housing and Support to provide a small scale development aimed at providing semi-independent housing with arm’s length support, along with some on-site communal facilities for those with housing needs.

The support for the principle of development identified by draft allocation HOU10 and supporting text at paragraph 4.64 is welcomed. Our client confirms that the area identified within the draft allocation boundary is surplus to requirements for car parking and alternative residential use in this location will not impact upon the operational requirements of the Bedford Heights site. However, our client does not support any suggestion that the area identified for allocation, or the extent of existing parking within this part of the site, should determine a capacity for development less than the 36no. units identified within its emerging proposals for development.

Draft Policy HOU10 is not positively prepared and not justified as it does not include a reference to the proposed capacity of the site (15 units) which is set out in Supporting Document 27 – Housing Trajectory. There is no recognition of different forms of developments (apartments) that could deliver a higher number of units on the site which would be a more effective and efficient form of development. Details of the 15no. unit capacity estimate are unsourced. They do not utilise the Council’s standard density multiplier of 30dph, based on the approx. 0.2ha site area, notwithstanding that our client would not agree with this assumption as it would fail to make best use of land within the urban area.

The ‘proposed use’ details within the Council’s HELAA Assessment Form (ID:7412) do recognise the suitability of flatted development in this location (30 units) and the evidence base is therefore inconsistent with details of capacity within the Housing Trajectory or Plan for Submission, albeit the HELAA fails to fully reflect the unit mix and associated capacity for emerging proposals at the site.

Two rounds of pre-application engagement have been undertaken on the proposed development of bespoke affordable housing development. Ongoing discussions and dialogue have taken place to discuss issues relating to technical comments and design aspects.

A project exhibition was hosted on the Bedford Heights site on 28th April 2022, which provided all residents with the opportunity to review the scheme and raise concerns / questions. A consultation website was also launched to allow comments to be made. Discussions have also been taking place with the Council’s Housing Team.

The proposed development of 36 affordable housing units (1-bed) is a carefully designed, sustainable development.

The Key Principles of the development set out in the draft Policy are commented on below:

i. Preparation by the applicant of a masterplan and design code to be complete prior to and submitted with any planning application and to pay particular attention to the adjacent noise sources, layout and massing of the site having regard to its elevated location;

We support the principle of supporting information to demonstrate how the design of the site has evolved and full consideration has been given to key constraints of the site. The proposed development of the site by IMPAKT Housing & Support will be fully supported through a Design and Access Statement. The size of the development site is considered to be quite small for such a specific requirement for a Masterplan and Design Code and is not justified. The planning application will be prepared in accordance with national policy and best practice on design in the absence of a Local Planning Authority design code.

ii. Access from Brickhill Drive;

We support that the proposed development should provide an access from Brickhill Drive. The proposed development utilises the existing car park access from Brickhill Drive.

iii. Provision of safe pedestrian and cycle links to adjacent networks;

We support that the site should have provision of safe pedestrian and cycle links. It is well located in a sustainable position for nearby services and facilities.

The proposed development is located on an area of existing car parking. This is lightly used with significant spare capacity in the immediate and wider surrounding Bedford Heights areas.

Covered and secure and short stay cycle parking will be provided in line with Council requirements. The quantum of car parking will reflect IMPAKT Housing & Support’s experience of developing and managing similar affordable schemes through the UK. Electric vehicle charging and DDA compliant spaces will be provided in line with Council guidance.

iv. Landscaping on and around the site to soften the interface with the adjacent car park;

We support the provision of landscaping to soften the development. This is proposed to be incorporated as part of the scheme currently being prepared.

v. Financial contributions towards secondary school provision;

This requirement appears to have been applied to most of the draft housing allocation sites within the Local Plan.

Support Document 16 – Bedford Infrastructure Delivery Plan, Section 6.2 covers Secondary Education. This looks at the demand for secondary education to 2040 and makes reference to the Bedford Borough Council (2013) Planning Obligations Supplementary Planning Document that assumes there are 21 secondary school aged children for every 100 dwellings built. Within paragraph 6.2.21 reference is made to small sites being required to make CIL or S106 payments to help fund the extension of existing schools or to fund the creation of a new school in the vicinity. There is no specific reference to the type of housing developments proposed and is therefore not justified or positively prepared.

In this case the proposal is for 36 1-bed dwellings which will generate no school age children and will therefore not generate a need in secondary education infrastructure terms. The policy is not flexibly worded to allow for consideration of a range of sizes of dwellings and the different requirements of these in terms of school age children. In accordance with the proposed saved Policy 33 of the Bedford Borough Local Plan 2030 there would be no adverse impacts to secondary education required to be mitigated through the proposed development of the site in accordance with the proposed 36, 1-bed dwellings and would therefore not meet the statutory tests set out within the CIL Regulations 2010 echoed in paragraph 57 of the NPPF (2021). The draft policy criterion is therefore not consistent with national policy.

vi. Delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change;

We support this key principle and the applicant for the development has aspirations for it to be one of the highest performing developments within Bedford in respect of sustainability, adopting a fabric first approach and extensive use of renewable technology.

vii. Early engagement with Anglian Water is required in order to identify connection to water network infrastructure

We support this principle and technical liaison will take place with the applicant’s drainage engineers to establish connections and adequate provision is made for water supply and surface and foul water disposal.

Comment

Representation ID: 9661

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DM1(S) is supported with reservations regarding the soundness of the policy. It is not positively prepared as it makes no reference to developments of 100% affordable housing or allow for flexibility for developments to come forward with a specific type of affordable housing to meet an identified need.

The Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update (Supporting Document ID 19), in Figure 9 sets out a total affordable housing requirement for 1-bedroom affordable dwellings of 1,218 units for the period 2020 to 2040 including 936 units for those unable to afford market rents.

Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Without prejudice to the prospect of our client providing a more detailed assessment of affordable housing need as part of a review of the Council’s own evidence, it is evident from its own position that the identified annual need for around 345 units is substantially below current levels of delivery (192 units for 2020/21 within the Council’s most recent interim Housing Monitoring Report) or secured as part of new permissions (150 units) over the same period. This needs to be viewed in context of the substantial current identified unmet affordable housing need recognised in the Council’s own LHNA (1,419 units unable to afford rents – see LHNA Addendum Figure 4) and the implications of the Council’s proposed stepped trajectory in delaying future needs associated with meeting local housing need in full (see separate representations to Policy DS3(S)).

Schemes making provision for a higher proportion (including 100%) of affordable housing provision early within the plan period, and specifically where in highly sustainable urban locations consistent with the Council’s wider strategy, should be expressly supported in the policies of the Local Plan 2040.

The proposed development at the Land at Bedford Heights is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Draft Policy DM1(S) is not effective as it does not account for developments that may provide a higher proportion of affordable homes than the 30% provision set out and contribute towards meeting identified affordable housing needs earlier within the proposed plan period.

The reference and requirement within draft Policy DM1(S) for First Homes is not positively prepared and not effective as no provision is made for any exceptions to this policy requirement. The proposed development at the Land at Bedford Heights proposes 100% affordable, 1-bed dwellings to meet a specialist form of housing that is otherwise in short supply and which caters for a specific need that is not generally met as a proportion of the housing mix secured via conventional planning obligations for affordable housing. Draft Policy DM1(S) does not allow for this situation and does not therefore accord with para.63 b) of the NPPF to contribute to the objective of creating mixed and balanced communities.

The draft Policy also does not reflect the NPPF para 72 that supports the development of entry-level exception sites. The Council’s Housing Strategy 2021-26 echoes this support for schemes in excess of policy compliant affordable housing at para’s 6.3.6, page 41 and 6.4.12, page 45. This support is not reflected in the draft Policy. As such the Council’s Housing Strategy should be referred to within the supporting text to Policy DM1(S) where this would encourage a positively prepared approach that supports opportunities to meet affordable housing needs in full.

Comment

Representation ID: 9664

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DS3(S) is supported with reservations regarding the soundness of the policy.

Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes. The Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update, in Figure 9 sets out a total affordable housing requirement for 1 bedroom affordable dwellings of 1,218.

The Council’s delivery timeframes and capacity assumptions in relation to our client’s site are incorrect. We do not, as a matter of principle, support the Council relying on a stepped trajectory as it delays meeting the identified minimum annual local housing needs for the Borough, particularly those relating to affordable housing. Suitable sites in the urban area such as our client’s site at Bedford Heights should be prioritised. This is mandated by Planning Practice Guidance ID: 68-021-20190722. In the Council’s circumstances it is essential that its assumptions regarding housing land supply are informed by developer engagement and reflect realistic details in relation to lead-in and build out rates (ID: 3-022-20190722). Fundamental shortcomings in the Council’s evidence base relating to our client’s site mean we must object to Supporting Document 27 – Stepped Housing Trajectory Topic Paper.

This shows an estimated capacity for the site of 15 units to be delivered in 2026/27 which is not justified, positively prepared and not consistent with national policy.

The site for the draft allocation HOU10 is shown on the revised Map 1 (Supporting Document 52 – Changes to Policies Map) however no evidence has been provided to justify the capacity of the site based on site area. Supporting Document 9 – Development Strategy Topic Paper May 2022 sets out that Bedford Heights draft allocation HOU10 is allocated as it is within the urban area. It is acknowledged that some urban sites are complex and may therefore result in a later delivery but these related constraints are not applicable to our client’s land, as outlined below.

Supporting Document 14 – Housing and Employment Land Availability Assessment and Site Assessments includes within Appendix 5 the Bedford Heights Call for Sites report extract (ID:7412). This highlights comments from key consultees but raises no significant issues that would restrict delivery of the site for residential development before 2026/27.

Details of the 15no. unit capacity estimate are unsourced. The Council’s estimates does not utilise the Council’s standard density multiplier of 30dph, based on the approx. 0.2ha site area, notwithstanding that our client would not agree with this assumption as it would fail to make best use of land within the urban area.

The ‘proposed use’ details within the Council’s HELAA Assessment Form (ID:7412) for the site does recognise the suitability of flatted development in this location (30 units) and the evidence base is therefore inconsistent with details of capacity within the Housing Trajectory or Plan for Submission, albeit the HELAA fails to fully reflect the unit mix and associated capacity for emerging proposals at the site.

A planning application is currently being prepared and all required technical reports being undertaken to meet all policy requirements. The application is to be submitted in Q3 of 2022/23 and it would be likely that development could commence on site in 2023. With a modular construction methodology and due to the limited scale of the development this site could realistically deliver the units in 2023/24.