Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9971

Received: 29/07/2022

Respondent: Gladman Developments Ltd

The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for housing and other development can be produced.
The NPPF requires that plans set out a vision and a framework for future development and seek to address the strategic priorities for the area. Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered ‘sound’.
The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.
In particular, paragraph 16 of the NPPF states that Plans should:
“a) Be prepared with the objective of contributing to the achievement of sustainable development;
b) Be prepared positively, in a way that is aspirational but deliverable;
c) Be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e) Be accessible through the use of digital tools to assist public involvement and policy presentation; and
f) Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).”
To support the Government’s continued objective of significantly boosting the supply of homes, it is important that the Bedford Local Plan 2040 provides a sufficient amount and variety of land that can be brought forward, without delay, to meet housing needs. In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs (LHN) assessment defined using the standard method. LHN sets the minimum number of homes required and this is the starting point for determining the number of homes required in any local planning authority area, unless there are circumstances to justify an alternative approach.
Once the minimum number of homes that are required is identified, the strategic planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 68 sets out specific guidance that local planning authorities should consider when identifying and meeting their housing needs, with Annex 2 of the NPPF providing definitions for the terms “deliverable” and “developable”.
Once a local planning authority has identified its LHN, these needs should be met as a minimum, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so, or the application of certain policies in the Framework would provide a strong reason for restricting the overall scale, type and distribution of development (paragraph 11b)i.). Where it is found that full delivery of housing needs cannot be achieved (owing to conflict with specific policies of the NPPF), local authorities are required to engage with their neighbours to ensure that identified housing needs can be met in full (see paragraph 35).
The July 2021 revision to the NPPF provides greater focus on the environment, design quality and place-making alongside providing additional guidance in relation to flooding setting out a Flood Risk Vulnerability Classification at Annex 3, the importance of Tree-lined streets and amendments to Article 4 directions. Moreover, Local Plans which had not yet progressed to Regulation 19 stage should ensure that where strategic developments such as new settlements or significant extensions are required, they are set within a vision that looks ahead at least 30 years. The Regulation 19 Bedford Local Plan 2040 has no such vision for a 30-year period.
Vision and Objectives
The NPPF is clear that where development plans are proposing large scale developments such as those within the Bedford Local Plan 2040, policies should be set within a vision that looks further ahead, at least 30 years, to take account the likely timescale for delivery. The vision should therefore be amended and updated to reflect this requirement of national policy.

Comment

Representation ID: 9972

Received: 29/07/2022

Respondent: Gladman Developments Ltd

It is acknowledged that the planning system has an important role to play in tackling the effects of climate change. In this respect, the overarching environmental objective of sustainable development cited in paragraph 8 of the National Planning Policy Framework highlights how the planning system should help to mitigate and adapt to climate change, and support the transition to a low carbon economy.
This objective filters through to other elements of the Framework, including Section 14 that deals specifically with Meeting the Challenge of Climate Change. In this regard, paragraph 152 of the Framework identifies how the planning system should:
“support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure”
Gladman therefore recognise the increasing importance of tackling climate change and encourage sustainable housing developments to mitigate its impact. The Council should continue to take account of climate change in its plan-making, including any updates to guidance in relation to the Framework and PPG. It is important to recognise that mitigating and adapting to climate change must also be compatible with other important objectives for the planning system, including the requirement to boost housing delivery and build a strong, competitive economy.
Bedford Borough Council have declared a climate emergency and Gladman is committed to contributing towards providing solutions to address these concerns. Gladman takes climate change seriously and our sites across Bedford can deliver numerous environmental commitments to assist the Council in meeting its climate related strategies:
Provision of Public Open Space
Well-designed open space will support an active lifestyle, by encouraging people to walk and cycle. It can also assist in terms of climate change resilience, through the provision of tree planting providing shading and CO2 absorption.
Sustainable Transport Methods
Our sites will deliver a comprehensive package of pedestrian and cycle infrastructure which will promote sustainable transport, including a suite of practical measures aimed at reducing traffic impact. All our sites could potentially deliver new bus stops and electric vehicle charging points, subject to further discussion with the Council and relevant stakeholders.
Renewable Energy & Energy Performance
Renewable energy technologies will be considered at the detailed design stage. These proposals will follow energy performance and efficiency targets, using a fabric-first approach to construction with the aim of reducing CO2 emissions.
Construction Management Plan
A construction management plan will be submitted at the reserved matters stage, which will put in place best practice measures such as re-using topsoil where possible, modern methods of construction and keeping landfill waste to a minimum.

Object

Representation ID: 9973

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

DS2(S) Spatial Strategy
Gladman are seeking changes to the spatial strategy of the Local Plan. More small and medium sites should be allocated to ensure that housing delivery can be increased in the short term to a level required by the standard methodology.
The spatial strategy can be summarised as growth opportunities within the Bedford urban area, strategic expansion of the urban area and strategic sites in transport growth corridors. Even growth to the villages is of a strategic scale. The nature of the sites proposed mean that housing delivery will not increase in the short term. Sites in the urban area may not be immediately available and the strategic sites are reliant on proposed strategic infrastructure.
We have submitted detailed commentary around the SA and the testing of options including village growth and we feel that any spatial strategy that overlooks the pivotal role growth in the villages can play in the timely delivery of housing is unsound.
The Council has deliberately sought to avoid allocating growth to settlements that were required to take growth in the adopted local plan, yet this plan only covers the period to 2030. There would be a ten-year period where these settlements are receiving no additional housing growth, set against a backdrop of the acute affordability issues across Bedford this is only likely to increase unaffordability in the villages. There will be a housing need in the villages beyond 2030 but this not currently addressed in the pre-submission draft. Another opportunity to increase housing delivery in the shorter term is a reconsideration of sites adjoining/adjacent to the urban area. However, the Council have opted to include only two strategic scale sites, adjacent to urban areas, on the basis of a green and blue infrastructure led approach. Concerns around potential coalescence are noted, but there are sites available to the Council in close proximity to the existing urban area that can contribute to the provision of green infrastructure whilst also delivering housing in the short term.
The inclusion of two new garden settlements to deliver a significant proportion of development in the latter stages of the plan period is a concern from a deliverability perspective. New settlements can play an important role in the delivery of new housing to meet the needs of a district, whilst avoiding some of the major constraints that may limit development elsewhere. However, the lead-in time and delivery of such schemes must be realistic and it is unlikely that these will start to deliver units in the first five years of the Plan. Therefore, any new settlements must be complemented by a range of additional smaller scale sites in both urban and rural locations that will deliver units in the early part of the plan period and provide flexibility if the larger sites do not deliver as quick as anticipated. If large scale housing targets are to be met a range of sites of differing scales and locations is vital.

Object

Representation ID: 9974

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS3(S) Amount and Timing of Housing Growth
The Local Plan is proposing to set a housing requirement of 27,100 between 2020 and 2040. This equates to an annual housing target of 1,355 using the standard methodology for calculating housing needs.
PPG clearly states that the standard methodology is merely the starting point for calculating housing need and only provides the minimum number of homes needed to meet the demographic baseline of housing needs. It is important that the housing needs of Bedford are not under-estimated.
Further consideration of the local circumstances of the area and the aspirations the Council wishes to achieve should be considered in determining the number of homes needed. This can include resolving historic housing under delivery, increasing economic output of the area, boosting affordable housing supply and the delivery of key infrastructure projects. Consideration should also be given as to whether the local authority is able to assist neighbouring authorities with their unmet housing needs. All of these factors should ultimately inform the final housing requirement for the Plan.
In the context of Bedford, the aspirations and implications of the Oxford-Cambridge Arc should not be under-estimated. Sitting centrally within the arc the potential economic boost of two planned new stations along the East West Rail (EWR) could have significant implications for economic growth and housing need. It is important that employment growth and housing growth are aligned so as to ensure unsustainable commuting patterns are not formed. However, it must also be noted that at the time of writing there are emerging doubts about the EWR proposals through the borough.
Stepped Trajectory
The Council are proposing to use a stepped trajectory for the delivery of housing. Continuing the housing target (970) of the Local Plan 2030 for the first five period, a minimal increase to 1,050 for the second five year period and a significant increase from 2030 onwards to 1,700 dwellings per annum when the strategic infrastructure, that a number of allocations are reliant on, is scheduled to be completed. Doubts have recently emerged around the Government’s commitment to this infrastructure and this could have serious implications for the plan as a whole.
Gladman strongly object to this approach. Whilst we recognise that the increase from the adopted housing target to the use of the standard methodology is a large increase, this is mainly due to the affordability adjustment of the calculation due to the inherent unaffordability of the borough. Seeking to defer meeting the needs established using the standard methodology is only likely to compound affordability issues and does not represent a positively prepared local plan. More should be done to address this increase in the short term. The apparent need for the stepped trajectory is a due to a deliberate choice from the Council to favour a strategy of two Garden Settlements, expected to deliver in the later stages of the plan period. Whilst these Garden Settlements are linked to large scale strategic infrastructure projects the rate of delivery expected on these sites is very ambitious in the latter part of the plan period and there is scope for this to roll on beyond the plan period.
Delivery rates reaching up to 600 dwellings on a single development for, a number of years is highly unlikely to be achievable, the Local Plan trajectory proposes this across two sites at the same time. Evidence from Lichfield’s second edition of the Start to Finish report3 on build out rates indicates that the average build out rate for sites larger than 2,000 dwellings is 181 dwellings per annum on average across the whole life of the development. Whilst recognising that build out rates can vary due to a number of conditions, 7 continuous years of delivery in excess of these figures and in 4 of years over double this rate is unprecedented.
Most of the housing delivery is proposed on these two sites in the latter stages of the plan period and by this stage it will be Impossible to address the failures of the strategy. Using a more realistic expectation around delivery rates on these sites would mean that the Council will not meet the minimum housing requirement. A significant failing of the proposed strategy.
This would also be likely to adversely affect the vitality and viability of services in existing settlements and result in a lack of housing choice in the market. It would also be difficult to accommodate changes in demand for certain types of development/services required over the very long period being committed to within the current strategy.

Comment

Representation ID: 9975

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Policy DS4(S) Amount of Employment Growth
The level of growth should be based upon a robust assessment of anticipated job growth, especially in light of the Council’s role within the Oxford Cambridge arc. This should also be considered in the context of housing needs.
The level of job growth is broadly the same as the housing requirement suggesting 1 new job per 1 new dwelling. The relationship between new homes and jobs should be carefully considered.

Object

Representation ID: 9976

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5(S) Distribution of Growth
This policy sets out the components of the spatial strategy. The Local Plan 2040 makes allocations for up to 13,550 new homes within the plan period, with 400 homes expected beyond the plan period.
Gladman has already submitted detailed commentary on the spatial strategy to policy DS2 and the SA and so will not rehearse these points again here.
The 13,550 new homes combined with commitments, windfall allowance and completions of 14,824 dwellings this is a total of 27,834 against the requirement of 27,100. This only represents a flexibility factor of 2.7% above the minimum housing requirement, or just over one year’s delivery at either Garden Settlement.
To safeguard any slippage in the anticipated trajectory of these large strategic sites the over-provision in the plan period should be increased. There is no hard and fast rule for what this over-provision should be but, Gladman supports the Home Builders Federation’s recommendation that local plans should seek to identify sufficient deliverable sites to provide a 20% buffer between the housing requirement and supply.
Without identifying further small and medium sites to deliver in the early part of the plan period there is a real risk that the minimum housing requirement of the Local Plan will not be met.
The Councils Local Plan strategy as currently set out has insufficient flexibility to be considered sound. A minor change to the delivery timescales of one of the new settlements would see the whole plan (already significantly backloaded in terms of delivery) fail to achieve its targets.

Comment

Representation ID: 9977

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Policy DM1(S) Affordable Housing
Policy DM1(S) sets out that at least 30% affordable housing is to be delivered where residential development proposals consist of 10 dwellings or more. The policy goes on to state that 25% of the total affordable housing requirement will need to be provided as First Homes.
At least 10% of total homes on developments sites should be available for affordable home ownership in accordance with Paragraph 65 of the Framework. This 10% requirement was first introduced in the 2018 Framework and included property tenure types such as Intermediate Shared Ownership.
Gladman can confirm that our site interests can accommodate this emerging policy requirement.

Comment

Representation ID: 9978

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Policy DM5 Self-build and Custom Housebuilding
Policy DM5 requires all sites of 5 or more dwellings to include provision of plots for self-build and custom housing as part of an appropriate mix of housing.
Gladman broadly support the inclusion of a policy in respect of self-build and custom-build housing in line with current government thinking and objectives. We consider it essential, however, that the policy wording rather than the supporting text should state that once a self-build and/or custom-build plot has been marketed for 12 months but failed to sell, it will revert to consideration by the Council to be built out as conventional market housing.

Object

Representation ID: 9979

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM6 Residential Space Standards
Policy DM6 seeks compliance with the Nationally Described Space Standards (NDSS), or any replacement standards produced by the Government, for all new homes including from change of use and conversion.
If the Council wishes to apply the optional NDSS to all dwellings, then this should only be done in accordance with paragraph 130f and footnote 49 of the NPPF. Footnote 49 confirms:
“49. Planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties. Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.”
Furthermore, with reference to the NDSS, the PPG confirms:
“Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies”.
If the Council wishes to adopt this optional standard, it should be justified by meeting the criteria set out in the national policy, including need, viability and impact on affordability.