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ID sylw: 108278

Derbyniwyd: 05/03/2025

Ymatebydd: David Kinnesley

Asiant : Fisher German

2.17 Whilst we do not object to the principal of the identification of a new settlement through this Plan, we would urge caution be applied if the Council rely on a new settlements delivery to meet the overall quantum of housing growth necessary over the Plan period. Large scale, freestanding communities are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered.

2.18 Our preferred approach in this scenario is to positively allocate such sites above and beyond the sites needed to meet housing needs, or at worst with highly cautious assumptions in terms of lead in times and annual build out rates. If work is underway and delivery has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which should provide the confidence needed to the market to commit to the works and evidence necessary to obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn’t come forward at all.

2.19 This approach also means the Council retain an element of control, meaning they can ensure the new settlement comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery. If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence and appropriate planning consents, then the Council can begin to rely on delivery as part of its housing figures.

2.20 Given the likely lead in times, assumed in excess of 7 years supported by evidence documents such as Lichfield Start to Finish Volume 3, Saville’s Housing Saville’s Planning and Housing Delivery and the Letwin Review, it is considered unlikely any development will be forthcoming on such sites until the latter end of the Plan period. This approach however could provide supply and certainty in the long term and an important avenue for future delivery, whilst ensuring a healthy housing land supply to ensure continued choice and competition in the market and not ‘putting all eggs into a single basket’.

2.21 Your attention is also drawn to correspondence of the ongoing Bedford Local Plan Examination where Inspectors concluded recently that build out rates assumed by the Council on the two proposed strategic sites were wholly unrealistic and that there was very little flexibility in the remainder of the Plan. The result being the Council now need to find additional sites to give the Inspector’s assurances that the housing requirements can reasonably be met.

2.22 The Inspector’s letter of the 27 November 2023 sets out these fundamental concerns. Paragraph 53 states “the delivery rate for larger sites is also naturally constrained by traditional factors that would exist regardless, such as master planning and arriving at an acceptable scheme, opening up, providing infrastructure, and resource availability. As such, attaching a high level of premium to delivery rates due to Corridor growth is not a justified approach. It is instead more logical to take a cautious attitude to this issue”. Paragraph 54 continues “Overall, I am not satisfied that the assumed build out rates for either Little Barford or Kempston Hardwick are based on justified assumptions that are soundly based. This is the case before factoring in the uncertainty around infrastructure delivery timings discussed above and is a view that only hardens once the two issues are considered alongside each other”.

2.23 With regards for implications, paragraph 55 states “as discussed above, the soundness of the spatial strategy (and therefore the Plan) is fundamentally linked to the deliverability of strategic infrastructure and the reasonableness of the assumptions on alignment with anticipated growth”. It continues “in addition, the assumed build out rates for the two new settlements on which so much of the Plan’s growth relies upon are not based on justified assumptions”.

2.24 Paragraph 56 states “by the Council’s own acceptance, the Plan has very little flexibility built in that may assist with managing either of these issues”, concluding that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)”.

2.25 Taking all relevant factors into consideration, the Inspector’s letter concludes at paragraph 57 and 58 that “from the evidence presented, I am not satisfied that housing needs after 2030 would be addressed as anticipated, leaving an overall gap in provision against assessed needs within the Borough across the entire plan period (including affordable housing)… Taking the three issues of assumptions around infrastructure delivery, build out rates, and the reliance on a stepped trajectory together, I am unable to conclude that the Plan meets the tests of soundness at paragraph 35 of the NPPF”.

2.26 It is apparent any strategy which places overreliance on such delivery risks falling foul of the same issues at EiP. A cautious approach is therefore entirely sensible if there is to be the identification of any new settlements as part of the emergent spatial strategy.