Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10073

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Our client wishes to raise an objection to proposed policy DM1(S) of the Local Plan 2040 – Plan for Submission.

Our client raises concern that sites brought forward with the affordable housing split purely as 75% affordable/social rent and 25% First Homes (to be sold by the developer at a 50% discount) will mean many sites will be unviable to deliver, because:

1. The split does not appear to facilitate the provision of shared ownership within the tenure mix; and
2. The requirement for First Homes to be sold at a 50% discount may not be viable, and significantly exceeds the Government's starting point of 30% discount.

The current tenure split in Bedford Borough in Policy 58S of the Local Plan 2030 allows for 78% rent (social and/or affordable rent) and 22% other affordable tenures (i.e. shared ownership).

The current tenure split means that Registered Providers can offer on the full affordable housing, but in the new proposals, they would only be able to offer and provide the rented tenures, wiping out much needed and popular shared ownership housing from those in need but also from the Registered Providers themselves. Registered Providers rely upon shared ownership to cross-fund the provision of social rented. We therefore must object to the statement in paragraph 6.13, that proposes the removal of shared ownership from the policy tenure mix, in favour of suggesting shared ownership be brought forward in “other contexts.” This position does not appear to have considered the role that this tenure plays both in meeting affordability, and in its support of social and affordable rental.

Currently, shared ownership can be sold at only 25% equity share compared to the proposed 50% in first homes meaning a mortgage for families will be more out of reach going forward as they may use the 25% initial equity share to get on to the property ladder and eventually work up to more whilst aspiring to come out of affordable housing.

We are concerned therefore the First Homes proposal will penalise many first-time buyers, especially young families who rely on shared ownership to be able to buy their first family home.

Moreover, as a high level worked example if a 3 bedroom house valued at £300,000 was to be sold as a first home the 50% mortgage required would be prohibitive to many people on the affordable housing waiting lists such as first-time buyer young families, whereas in the current mix this same house would be able to be accessed with a mortgage on only 25% of the equity enabling such young family to be in this tenure of affordable housing instead of then burdening the affordable rent housing waiting lists. This could further exacerbate affordable rent waiting lists in the borough and increase the need for this tenure putting more pressure on the Local Authority.

The findings of the BNP Paribas Borough Wide Viability Study do not provide convincing evidence that the First Homes discount of 50% does not harm the viability of residential schemes coming forward. The statement in paragraph 8.8 of the viability report appears to accept that viability is questionable, that the 30% affordable housing provision is not itself completely justified, and reference to that target being generally achievable does not identify that this is either when tested against the “lower benchmark land value” or makes the assumption that “grown values and costs” will address the viability in the longer term. It also confirms in paragraph 8.11 that the proposed housing policy does not support the viability of Build to Rent schemes. In our opinion, there is an over-reliance upon growth and flexibility in the policy to address such matters on a site-by-site basis.

This conclusion supports our position that the viability of these proposals remains questionable, and our client, therefore, reserves the right at this stage to undertake their own viability assessment, and make further representations at the Examination.

We, therefore, contend that the policy as drafted could result in an adverse impact on affordability in the Borough, and harm the viability of future residential development. The policy is therefore not effective or justified and renders the plan UNSOUND.

Comment

Representation ID: 10074

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Please refer to the representations contained in attached the document “195345 - LP2040 Statement of Representations DS2S_DS3S_DS5S” prepared by Phillips Planning Services Ltd.

The representation contains our clients’ responses to policies DS2(S), DS3(S) and DS5(S) in respect of their interests in Land west of the village of Great Barford south of the A421 – site ID 878.

The statement has been compiled to follow the Council’s desired format.

In our opinion, the Council’s proposed Spatial Strategy, as defined under Policy DS2(S) is undermined by the risks we have identified in the Stepped Trajectory
set out in Policy DS3(S). We wish to raise concerns that the Spatial Strategy does not sufficiently address the potential for delays in the delivery of East-West Rail,
and other key infrastructure required to support the proposed strategic allocations on the East-West Rail / A421 transport corridor. Paragraph 4.3
concisely captures the main elements of the Council’s strategy and states:
“The completion of EWR will result in the creation of highly accessible locations around new rail stations. By concentrating on accessible locations, the spatial
strategy aims to minimise the need to travel by car and therefore reduce the emission of carbon dioxide in line with the objectives of the plan. The growth locations are as follows:
A. Within the urban area
B. At strategic locations adjacent to the urban area which contribute to the delivery of key green infrastructure projects
C. At new growth locations focussed on the EWR / A421 transport corridor with the potential for rail based growth, particularly in the south of Bedford area and
at a new settlement at Little Barford.”
Given the slow progress of detailed proposals for East-West Rail between Bedford and Cambridge, and uncertainties surrounding when this piece of major
infrastructure will eventually be delivered, the reliance on the Stepped Trajectory to meet the identified housing and employment needs, set out in Policy DS3(S), appears to be highly optimistic, and does not positively plan for the potential of a slower rate of housing delivery, or a delay in the commencement of development on the identified new settlements South of Bedford and at Little Barford.
The Council’s proposed residential development trajectory in the years 2030-2040 is therefore not realistic nor deliverable. We would contend that East-West
Rail will take longer to come forward, and that the Council is likely to fall far short of achieving the requisite 1,700 dwellings per annum in the years 2030-2040.
The risks surrounding the delivery of EWR are acknowledged in the ‘Development Strategy Topic Paper’ (June 2021). In the analysis of the ‘Option 2’ sub-options i.e. Development in and around the urban area, plus A421 transport corridor with rail based growth plus one or two new settlements. In the ‘Weaknesses and delivery challenges’ assessment of the reasonable alternatives
for Option 2 the Topic Paper states:
• Viability and land assembly challenges for urban land and timing of delivery in some cases dependent on EWR delivery;
Delivery of new rail stations is proposed, but not yet confirmed.”
While we recognise that the Council is acknowledging these risks stating it will monitor the provision and delivery of infrastructure and, if necessary, bring
forward a review of the Local Plan, we would contend that for the plan to be positively prepared and effective, the plan should attempt to mitigate these known risks through an appropriate policy framework to be put forward now, in the Local Plan 2040, rather than postponed for another review.
This Spatial Strategy is therefore not effective, nor is it positively prepared to address the potential weaknesses in the strategy during the plan period. We would contend that this would make the plan, as submitted, UNSOUND.

Comment

Representation ID: 10075

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Following on from our representation in respect of Policy DS2(S), the proposed
Stepped Trajectory under Policy DS3(S) is optimistic and carries with it a high risk
of failure, with no mechanism evident to mitigate that risk. The Council is
adopting a stepped approach to housing delivery, where the current Local Plan
2030 provides for 970 dwellings per annum to 2024/25, then a marginal uplift is
planned for 2025/26 to 2029/30 (following adoption of the Local Plan 2040), and
then the expectation of a significant increase to 1700 dwellings per annum, from 2030/31 through to 2039/40.
The Council’s strategy for increased delivery in the years 2030-40 is a risky one
because the majority of the additional circa 12,000 new dwellings, that are
needed, are coming from the two new settlements in the plan, i.e. South of
Bedford and Little Barford. Both sites are allocated to provide at least 4,000
homes and each to a large extent are underpinned in transport terms by the
delivery of the new East-West Rail route.
The stepped trajectory assumes a sudden and immediate increase in housing
delivery in the year 2030/31. This assumption is based on a further assumption
that the identified infrastructure to support this growth is in place prior to 2030,
however, in terms of East-West Rail, the plan states at paragraph 4.23:
“The potential of EWR to offer improved connectivity and create economic growth
will be a critical catalyst for delivery and pivotal to achieving the plan’s vision. The
new links and stations however will not be operational until 2030 and other
essential infrastructure (principally improvements to the A421) are expected to be
delivered on similar timescales.”
In respect of the two new settlements the plan states that in respect of “South of
Bedford”, accessibility to the new settlement relies on the East-West Rail station
but delivery is unlikely before 2030 (see the South of Bedford Area Topic Paper
(April 2022)); and in respect of Little Barford the supporting technical note states
that it is proposed to increase public transport frequency considerably to meet
demand, and that a public transport hub is necessary with the new station at the
heart of this new settlement. The Little Barford settlement appears to be highly
reliant upon significant changes to the wider infrastructure network to
accommodate the projected growth, without such improvements it is unclear that
the existing highway network could accommodate the projected growth without
significant adverse impacts in the area immediately south of St Neots.
In our opinion, there are contradictions within the plan, where it assumes a massively increased development trajectory from 2030 onwards but at the same
time states that the new East-West Rail and other key road infrastructure will not
be ready before 2030. It does not therefore appear to plan for the possibility that
the critical supporting infrastructure, that this approach relies upon, will not be
ready until into the 2030s, either on current evidence or more so if there is a
delay.
Given that the trajectory may well slip the Council should take account of this risk
and seek to mitigate through the improved use of existing identified sites, such as
Great Barford West allocation of additional sites, or the identification of strategic
reserve sites, that remain inline with the adopted strategy, and could come
forward in the late 2020s should this strategic infrastructure be delayed.
The NPPG states the following in respect of reserve sites (emphasis added):
“Where strategic policy-making authorities are unable to address past shortfalls
over a 5 year period due to their scale, they may need to reconsider their
approach to bringing land forward and the assumptions which they make. For
example, by considering developers’ past performance on delivery; reducing the
length of time a permission is valid; re-prioritising reserve sites which are ‘ready
to go’; delivering development directly or through arms’ length organisations; or
sub-dividing major sites where appropriate, and where it can be demonstrated
that this would not be detrimental to the quality or deliverability of a scheme.”
The identification of reserve sites is therefore recognised as an appropriate part
of the plan-making process. Identifying reserve sites would provide the Council
with an insurance against a fall in housing supply and will give the Council more
time to undertake a Local Plan review in the late 2020s should East-West Rail and
the improvements to the A421 be delayed. Without adequate insurance through
further allocations or the identification of strategic reserve sites, policy DS3(S) –
Amount of housing and timing of housing growth, has not been adequately
justified by the evidence base and will note be effective in meeting the Borough’s
housing needs. The stepped change in delivery is a high-risk strategy and inadequate mitigation is provided should that strategy fail to deliver due to delays
in the delivery of strategic infrastructure. On this basis the adoption of this policy
is considered to render the plan UNSOUND.

Comment

Representation ID: 10076

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Please refer to our representations in respect of proposed policies DS2(S) and
DS3(S) of the Local Plan 2040 – Plan for Submission. We raise objection to the soundness of the plan due to a reliance on stepped housing trajectory, reliant on
strategic settlement delivery in 2030, underpinned by the need to have
significant infrastructure in place before 2030. This is a high risk strategy and our
representations are that additional housing should be identified in the search
area, consistent with the spatial strategy, that will offer additional capacity; could
be delivered in phases in the late 2020s, or are held as strategic reserve sites to
be released for development should it become clear that delays in the delivery of
strategic infrastructure in the form of east-west Rail and improvements to the
A421 will delay or reduce the delivery of the identified new settlements on Land
South of Bedford and Little Barford.
On the basis of the above representations, Policy DS5(S) does not identify
sufficient allocations to mitigate for this scenario, nor does it take the
opportunity to identify strategic reserve sites that could be brought forward if
and when necessary to meet the shortfall in delivery rates.
Without adequate insurance through further allocations or identification of
strategic reserve sites, policy DS5(S) – Distribution of growth has not been
adequately justified by the evidence base and will not be effective in meeting the
Borough’s housing needs. The stepped change in delivery is a high-risk strategy
and inadequate mitigation is provided should that strategy fail to deliver due to
delays in the delivery of strategic infrastructure. On this basis the adoption of
this policy is considered to render the plan UNSOUND.