Central Bedfordshire Pre-submission Local Plan (January 2018)

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Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SP1: Growth Strategy

Representation ID: 9027

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

TARGETS - dispute housing calculations
STRATEGY - need a higher housing target
DtC - has not been met, not meeting unmet need


04

Full text:

Policy SP1 proposes a housing target of 39,350 new dwellings over the Plan period, which is comprised of 32,000 dwellings to meet the full objectively assessed need (OAN) for Central Bedfordshire, based on the Central Bedfordshire and Luton SHMA (January 2018), and a contribution of 7,350 dwellings towards Luton's unmet need.

Unfortunately, GPS Estates Ltd remain unconvinced that this housing requirement is based on a true assessment of the full need arising in the Housing Market Area (HMA) and as a consequence the Local Plan will fail to deliver sufficient housing over the plan period, contrary to paragraph 47 of the NPPF and the Planning Practice Guidance (PPG).

The PPG identifies that the CLG household projections are the starting point in determining OAN. The 2014-based CLG household projections are the most recent figures available. These indicate an overall growth requirement over the 20 year Plan period of 57,536 dwellings in the Luton HMA, which breaks down as 22,948 households required in Luton and 34,586 households in Central Bedfordshire. However, the SHMA concludes that the Full, OAN for the HMA is 50,588 dwellings, rounded up to 51,000, which is split between the two local authorities; Luton - 18,810, rounded up to 19,000 and Central Bedfordshire - 31,778, rounded up to 32,000.

Therefore, the outcome of the SHMA is a reduction of 6,536 dwellings from the total need for the HMA when compared to the CLG household projection starting point. For Central Bedfordshire in isolation the reduction is 2,586 dwellings. Pigeon has significant concerns that this will unduly mask housing need in direct contravention to Government policy.

The PPG expressly states that any decision to deviate from the CLG household projections need to be justified, yet the evidence in the SHMA is far from convincing. In particular, the use of the ten year migration trend is not considered to be appropriate as it results in the inclusion of two years during the last recession, 2008/2009 and 2009/2010, where migration fell significantly below levels prior to or since then, with the result being a negative impact on the average figure, which has then been applied to the forecast for the next 20 years distorting the position on need.

Given the lack of justification provided for the reduced housing need figures that have been arrived at in the SHMA, GPS Estates Ltd is of the view that the Council should revert back to utilising the CLG household projections and the housing requirement in the Pre-Submission LP should be amended accordingly. Such a position has been endorsed most recently by the Government in the "Planning for the Right Homes in the Right Places" consultation.

GPS Estates Ltd also has strong reservations over the approach adopted to market signals in the SHMA, with this again appearing to be at odds with recent Government advice. The "Planning for the Right Homes in the Right Places" consultation included details of the proposed approach to a standard method for calculating housing need, which was first mooted in the Housing White Paper "Fixing our Broken Housing Market" earlier in 2017. This proposed a standard method for calculating need by directly relating it to affordability ratios, whereby the higher house prices are in comparison to average local salaries, the higher the uplift that should be applied to the household projection figures. Based on the methodology outlined in the consultation there should be an uplift of 40% above the demographic starting point in Central Bedfordshire as a consequence of the affordability ratios exhibited.

Whilst it is acknowledged that the "Planning for the Right Homes in the Right Places" consultation paper can only be afforded limited weight at this stage, it does give a clear steer as to the direction Government intends to take with the standardised method for calculating housing need and also its commitment to tackling the housing crisis. By comparison, the SHMA has only adopted a 10% uplift for market signals in Central Bedfordshire, which Pigeon would suggest is unacceptably low given the acknowledged disconnect between house price increase and wages. Indeed, the supporting text to Policy H4 Affordable Housing, when commenting on increases in house prices in comparison to wages, specifically suggests 'this gives a stark depiction of just how serious the problem is'.

It is also telling that in response to the transitional arrangements also consulted upon as part of "Planning for the Right Homes in the Right Places" which would result in the substantially higher target based on the standardised method for calculating housing need becoming the housing requirement in the interim period before a new Local Plan is adopted, the Council immediately accelerated its timetable for preparing and submitting its Local Plan to avoid such a situation.

GPS Estates Ltd is therefore of the view that the Local Plan should be revised to include a higher housing target in order to respond to market signals and do more to tackle affordability issues within Central Bedfordshire, and to boost significantly the supply of housing (paragraph 47).

In respect of the contribution towards Luton's unmet need within the overall housing requirement in Policy SP1, whilst welcomed in principle, GPE Estates Ltd are concerned that this still leaves a shortfall against the unmet need, even on the basis of the Joint SHMA (January 2018) figure, which, as has been demonstrated above, is open to scrutiny on the basis it does not in fact calculate the true housing need for the two administrative areas within the best fit HMA.

The SHMA suggests that the Full OAN for Central Bedfordshire and Luton combined is 51,000 dwellings over the period 2015 - 2035, of which, 19,000 dwellings is the identified figure for Luton alone. The Luton Local Plan was recently adopted having been found sound by the Inspector on the basis that only 8,500 dwellings (425 per annum) can be delivered within its administrative area over the Plan period of 2011 - 2031 against an identified need (at the time the Plan was prepared) of 17,800 dwellings. On the basis that 1,700 (425 x 4) of the dwellings identified for delivery in the Luton Local Plan are intended to meet the need over the first 4 years of the Plan period (i.e. 2011 - 2014) this means that only 6,800 dwellings from that Plan should contribute towards the housing need total in the new SHMA, leaving 12,200 dwellings still to be found if this need is to be met.

North Hertfordshire District Council has proposed a contribution of 1,950 dwellings toward the Luton unmet need in its Local Plan, which is currently at examination. Aylesbury Vale District Council did not propose any contribution in its Pre-Submission Local Plan, which was the subject of consultation between 2nd November and 14th December 2017, on the basis it is providing housing towards the unmet need of other local authorities which HMAs overlap the boundaries of. CBC's contribution of 7,350 dwellings therefore still leaves a shortfall of 2,900 dwellings that none of the local authorities in the functional HMA are proposing to meet.

Paragraph 47 of the NPPF requires that local planning authorities 'use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area'. It is unclear from the evidence published with the Pre-Submission LP how, if at all, this remaining unmet need from Luton is to be dealt with to ensure the overall need within the HMA is met in full.

Whilst the Council has suggested that it intends to produce Statements of Common Ground with adjoining local authorities prior to Submission of the Plan, given the lack of technical evidence published with the Plan, it is impossible to say at this stage that the CBC's obligations under the Duty to Co-operate have been satisfactorily met as part of the preparation of this Plan.

GPS Estates Ltd presume a Memorandum of Co-operation/understanding with Luton Borough has been prepared and it is disappointing this has not been published with the Pre-submission LP, particularly given the reason the previous attempt to bring forward a development plan for the whole of Central Bedfordshire, the Draft Development Strategy, then failed was because the Inspector concluded that the Council had not complied with the Duty to Co-operate in preparing that Plan, with one of the specific issues raised being the fact that evidence was published after the Pre-Submission consultation on that Plan.

A fundamental concern the Inspector ultimately had with the Draft Development Strategy, was that the Council had not satisfactorily worked with the other authorities in the HMA, and Luton Borough in particular, to determine whether it could accommodate all of the Luton's unmet need; at that time the Council had only sought to contribute 5,400 dwellings. At paragraph 50 of his letter dated 16th January 2015, the Inspector stated:

"Furthermore, there is no evidence that the Council has considered the implications of meeting the unmet need of Luton in full. As many participants pointed out, a reasonable alternative for assessment through the sustainability appraisal process would have been an additional option with a housing figure somewhere between those of options 3 and 4. Ultimately this is a soundness point given the drafting of Framework paragraph 182. However, this also goes to the Duty since this has been an issue in contention between the two authorities since October 2010 at the latest and is thus indicative of a failure of the Duty process to influence the Plan since no accommodation on this important cross-boundary issue has been reached."

At paragraph 55 the Inspector went on to say:

".....Moreover, from the wording of the MoU and the way the signatories see it working in practice it seems reasonable to conclude that making provision for Luton's unmet housing need in an adopted plan or plans is some way off. Furthermore, it seems to me inevitable that the outcome of the MoU process will be that the requirement to provide for the whole of that unmet need will fall back on the Council in the first instance."

In the following paragraph the Inspector continued:

"In effect therefore the Council has deferred to later plans that either it or others will prepare an issue that it could and should have addressed now under the Duty. The necessary steps to secure effective policy delivery on cross boundary strategic matters have not been taken in respect of housing. I acknowledge that in considering this issue the distinction between a failure to comply with the Duty and a failure to agree with others (and LBC in particular) is a matter of judgement that is not always clear. In making that judgement however I consider it reasonable to conclude on the evidence that the Council has failed to comply with the Duty in that regard."

What is clear from the evidence put forward in the Luton HMA Growth Options Study (July 2017) is that there is further capacity within Central Bedfordshire to accommodate unmet need from Luton. For example, at paragraph 2.2 of the Executive Summary and Key Findings it states:

"..... It is also important to note that the overall capacity of the locations identified within the study through this process, far exceeds that which will be required within the plan".

On the specific point of accommodating Luton's unmet need, GPS Estates Ltd is of the view that the Pre-Submission LP is not currently sound. Firstly, it has not been 'positively prepared' as the LP has not been prepared based on a strategy which seeks to meet objectively assessed housing requirements, including unmet housing requirements from neighbouring authorities when it is clearly reasonable and appropriate to do so and consistent with achieving sustainable development.

For this reason the LP is also not consistent with national policy as it does not meet the requirements of paragraphs 47 and 179 of the NPPF in of ensuring the full, objectively assessed needs for market and affordable housing in the housing market area.

Finally, in this respect the LP can also not be considered 'justified' as it is not the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

In order to be considered sound the remaining unmet need from Luton over the Plan period needs to be planned for and there being robust evidence of how and where it is to be delivered.

Notwithstanding the comments above on how the housing target has been determined, a further concern of GPS Estates Ltd has is that it leaves insufficient headroom to provide flexibility and an in built contingency in case sites do not come forward as planned. The housing target is broken down in Tables 6.2 and 6.3, with 23,845 dwellings to being delivered from existing commitments (including existing allocations and sites with planning permission) and an allowance of 307 dwellings from windfall sites in the five year supply period), 15,405 dwellings are proposed from new allocations in the Plan (9,900 on strategic allocations and 5,505 on medium and small sites) and 2,520 as a further windfall allowance post 5 years.

Whilst specific comments are made on the Implementation section of the Plan directly regarding the delivery strategy and the overreliance on large strategic sites, GPS Estates Ltd are very concerned that the target in Policy SP1 allows insufficient headroom and therefore margin for error in delivery terms. Were the assumed level of housing from all of the sources in Tables 6.2 and 6.3 delivered it would amount 41,770 additional dwellings, an increase of 2,420 over the identified need, which as argued above, is itself not considered to be high enough.

This is a contingency of only just over 6%, which is not considered to be anywhere near robust enough and would not provide the flexibility suggested by the NPPF. As evidence of this you only have to look at the Housing Implementation Strategy (January 2018) which has been published as technical evidence in support of the Local Plan. At paragraph 4.2.1 this advises that when applying the Local Plan requirement from 1st April 2018 to 31st March 2023, including the estimated shortfall and a 5% buffer only a 5.09 years supply can be pointed. This is extremely marginal and it would only take one site not delivering as planned before the Council were in a position in which it cannot demonstrate a robust supply. As will be explained in detail in the representations on Section 7 Implementation, GPS Estates Ltd are very sceptical about the delivery estimates and are of the view that 5 year housing supply difficulties will inevitably be the result were the Plan adopted as proposed. This is very poor planning on behalf of the Council, particularly when it has spent much of the past 4 years in a position where it has made difficult decisions on 'ad hoc' unallocated applications because it cannot demonstrate a robust 5 year supply.

The previous version of the Local Plan suggested various housing target options that would involve a greater level of contingency above the housing need requirement to provide more headroom. It is unclear why this has not been followed through in the Pre-Submission Plan. If the reason is because of the intention to undertake an early review, GPS Estates Ltd would argue that this is not an appropriate mechanism for providing a contingency due to the time it takes to get a Local Plan in place.

It is therefore evident that irrespective of wider concerns about how the housing requirement has been arrived at, the Pre-Submission Local Plan target also fails include sufficient headroom in the level of housing it is seeking to deliver above the need to ensure flexibility and a robust contingency, with the inevitable consequence being the Council is going to immediately have difficulty demonstrating a robust 5 year housing land supply. The Plan cannot therefore be considered positively prepared, justified, effective or consistent with nationally policy as required by paragraph 182 of the Framework and GPS Estates Ltd would suggest that a substantial increase in the housing requirement needs to be introduced before the Plan can be considered sound.

Support

Central Bedfordshire Pre-submission Local Plan (January 2018)

4.2 The Strategic Objectives - How we will get there

Representation ID: 9029

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

GPS Estates Ltd support the overall key principle underpinning the emerging spatial strategy for Central Bedfordshire outlined in section 5 of the Plan. That being to seek to realise the opportunity for sustainable economic led growth provided by Central Bedfordshire's strategic geographical position on the axis of the Oxford to Cambridge corridor and key transport corridors to London; namely the M1, A1, Midland Main Line Railway and the East Coast Railway.

Full text:

GPS Estates Ltd support the overall key principle underpinning the emerging spatial strategy for Central Bedfordshire outlined in section 5 of the Plan. That being to seek to realise the opportunity for sustainable economic led growth provided by Central Bedfordshire's strategic geographical position on the axis of the Oxford to Cambridge corridor and key transport corridors to London; namely the M1, A1, Midland Main Line Railway and the East Coast Railway.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

6.6 Growth Strategy

Representation ID: 9030

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

TARGETS - Dispute housing calculations, Housing target is insufficient

05

Full text:

Policy SP1 proposes a housing target of 39,350 new dwellings over the Plan period, which is comprised of 32,000 dwellings to meet the full objectively assessed need (OAN) for Central Bedfordshire, based on the Central Bedfordshire and Luton SHMA (January 2018), and a contribution of 7,350 dwellings towards Luton's unmet need.

Unfortunately, GPS Estates Ltd remain unconvinced that this housing requirement is based on a true assessment of the full need arising in the Housing Market Area (HMA) and as a consequence the Local Plan will fail to deliver sufficient housing over the plan period, contrary to paragraph 47 of the NPPF and the Planning Practice Guidance (PPG).

The PPG identifies that the CLG household projections are the starting point in determining OAN. The 2014-based CLG household projections are the most recent figures available. These indicate an overall growth requirement over the 20 year Plan period of 57,536 dwellings in the Luton HMA, which breaks down as 22,948 households required in Luton and 34,586 households in Central Bedfordshire. However, the SHMA concludes that the Full, OAN for the HMA is 50,588 dwellings, rounded up to 51,000, which is split between the two local authorities; Luton - 18,810, rounded up to 19,000 and Central Bedfordshire - 31,778, rounded up to 32,000.

Therefore, the outcome of the SHMA is a reduction of 6,536 dwellings from the total need for the HMA when compared to the CLG household projection starting point. For Central Bedfordshire in isolation the reduction is 2,586 dwellings. GPS Estates Ltd have significant concerns that this will unduly mask housing need in direct contravention to Government policy.

The PPG expressly states that any decision to deviate from the CLG household projections need to be justified, yet the evidence in the SHMA is far from convincing. In particular, the use of the ten year migration trend is not considered to be appropriate as it results in the inclusion of two years during the last recession, 2008/2009 and 2009/2010, where migration fell significantly below levels prior to or since then, with the result being a negative impact on the average figure, which has then been applied to the forecast for the next 20 years distorting the position on need.
Given the lack of justification provided for the reduced housing need figures that have been arrived at in the SHMA, GPS Estates Ltd is of the view that the Council should revert back to utilising the CLG household projections and the housing requirement in the Pre-Submission LP should be amended accordingly. Such a position has been endorsed most recently by the Government in the "Planning for the Right Homes in the Right Places" consultation.

GPS Estates Ltd also has strong reservations over the approach adopted to market signals in the SHMA, with this again appearing to be at odds with recent Government advice. The "Planning for the Right Homes in the Right Places" consultation included details of the proposed approach to a standard method for calculating housing need, which was first mooted in the Housing White Paper "Fixing our Broken Housing Market" earlier in 2017. This proposed a standard method for calculating need by directly relating it to affordability ratios, whereby the higher house prices are in comparison to average local salaries, the higher the uplift that should be applied to the household projection figures. Based on the methodology outlined in the consultation there should be an uplift of 40% above the demographic starting point in Central Bedfordshire as a consequence of the affordability ratios exhibited.

Whilst it is acknowledged that the "Planning for the Right Homes in the Right Places" consultation paper can only be afforded limited weight at this stage, it does give a clear steer as to the direction Government intends to take with the standardised method for calculating housing need and also its commitment to tackling the housing crisis. By comparison, the SHMA has only adopted a 10% uplift for market signals in Central Bedfordshire, which Pigeon would suggest is unacceptably low given the acknowledged disconnect between house price increase and wages. Indeed, the supporting text to Policy H4 Affordable Housing, when commenting on increases in house prices in comparison to wages, specifically suggests 'this gives a stark depiction of just how serious the problem is'.

It is also telling that in response to the transitional arrangements also consulted upon as part of "Planning for the Right Homes in the Right Places" which would result in the substantially higher target based on the standardised method for calculating housing need becoming the housing requirement in the interim period before a new Local Plan is adopted, the Council immediately accelerated its timetable for preparing and submitting its Local Plan to avoid such a situation.

GPS Estates Ltd is therefore of the view that the Local Plan should be revised to include a higher housing target in order to respond to market signals and do more to tackle affordability issues within Central Bedfordshire, and to boost significantly the supply of housing (paragraph 47).

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

8.3 Green Belt release

Representation ID: 9039

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

GREEN BELT - dispute site specific conclusions of Green Belt study

04

Full text:

GPS Estates Ltd support the methodology of the assessment taken in Stage 1 of the Green Belt Review, and in particular, the conclusions reached in respect of parcel BC2, to the east of Barton-Le-Clay.

This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt - purposes 1, 2 and 4. The Review does conclude however that this parcel makes a relatively strong contribution to purpose 3, by assisting the safeguarding of the countryside from encroachment.

Parcel BC2 extends across a wide area of the Green Belt covering the whole of the east of Barton-Le-Clay. In the Stage 2 assessment of the Green Belt Review the site falls within a smaller sub-parcel BC2a which is assessed as having relatively weak contribution to the Green Belt. The Green Belt Review notes this area lies adjacent to the built edge of Barton Le Clay and includes Ramsey Manor Lower School and Arnold Middle School which has the effect of making a relatively weak contribution to purpose of including the land within the Green Belt. The assessment concludes the heavily-treed watercourse to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong potential alternative to the Green Belt boundary.

GPS Estates Ltd are of the view that the allocation of the Land at Manor Road would be a logical extension to Barton-Le-Clay on a contained site in an existing built up area. Development of the site would not harm the purposes of including the land in the Green Belt as it is located between the northern boundary of Ramsey Manor Lower School and Ivel Close, and sits directly to the west of the tree lined watercourse which could form a new edge to the settlement limits and an appropriate boundary between the built form and Green Belt beyond.

Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Manor Road and states "Areas of land that make a relatively limited contribution to the overall Green Belt would be where new development would effectively be 'infill', with the land partially enclosed by development; new development would be well contained by the landscape, e.g. with rising land; new development would be of little harm to the qualities that contributed to the distinct identity of separate settlements in reality; and, a strong boundary could be created with a clear distinction between 'town' and 'country'."

In terms of the five purposes for including land in the Green Belt (Para. 80 of the NPPF) the site is not of a scale such that its development would result in un-restricted sprawl of Barton-Le-Clay, it would not lead to coalescence with adjacent settlements, it would not lead to significant encroachment into the countryside, there would be no harm to the setting or special character of a historic town, and the allocation of the site would not prevent any derelict or urban land coming forward. The site itself therefore contributes nothing to the purposes of the Green Belt.

In dismissing the site as an allocation, the Council provide no substantial evidence to suggest the Green Belt review is incorrect in its findings. The assessment suggests
"the heavily-treed watercourse to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong potential alternative to the Green Belt boundary". This site is therefore a strong candidate for small scale site allocation which can make an important contribution towards the pressing housing need in the area.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

6.10 Summary of Housing Growth in Central Bedfordshire 2015-2035

Representation ID: 9046

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

STRATEGY - overreliance on strategic sites
DELIVERY - Dispute delivery of strategic sites, more small/medium sites needed.

05


Full text:

GPS Estates Ltd are not convinced the Pre-Submission LP can deliver the high level of housing required during the plan period due to an overreliance on sizeable strategic allocations. This reliance would most likely lead to a failure to meet the housing target, particularly in the early years of the Plan. It is therefore imperative that the
Plan allocates a higher proportion of the housing requirement to small and medium sized sites, which are generally less complicated and quicker to deliver, to ensure that the substantial housing need is met throughout the Plan period.

It is acknowledged that strategic housing allocations have an important role to play in formulating and delivering a sound spatial strategy to deliver the growth required over the plan period. However, GPS Estates Ltd do not consider that the spatial strategy as currently detailed within the Plan will deliver that growth. In this respect the plan is not positively prepared or justified.

More specifically, it is our clear view that the strategic allocations will not deliver the numbers of dwellings that are set out in the table on Page 46 of the Plan. There are several areas of concern. Firstly, we believe that the trajectory makes optimistic assumptions on when sites will start to deliver housing. The strategic sites are all scheduled to start delivery by 2023/24 but the two largest sites, North Luton and Marston Vale, are stated as delivering as early as 2022/23 and 2021/22 respectively. This is considered to be optimistic.

The North Luton allocation has been identified as a strategic allocation for growth for some considerable time. It was identified with the Luton and South Central Bedfordshire Joint Core Strategy and the Development Strategy for Central Bedfordshire. Both of those plans were withdrawn and not proceeded with. However, this did not preclude the development coming forward. The North Houghton Regis urban extension was also included in those documents and subsequently planning applications came forward back in 2012. North Luton has never come forward as an application. A Framework Plan was approved by the Council in March 2015 for development management purposes. The Council states that a new Masterplan will be prepared.

It is expected that there will be deliverability issues linked to viability. There is some funding in place towards the cost of delivering the link road between the M1 and the A6 but the majority of the costs will be met by the developer(s). Notwithstanding this, the timescale for delivery by 2022/23 is clearly very ambitious.

The stated delivery timescale for Marston Vale Villages is even more ambitious than North Luton, with units expected to be delivered in 2021/22. This is just three years from the date of this consultation. As with North Luton, a Development Brief needs to be prepared and approved prior to planning applications coming forward.

Research has been undertaken within the construction industry to establish lead in times for large strategic sites to deliver housing on site. Nathaniel Lichfield and Partners published a report 'Start to Finish' in 2016. The research found for sites of over 2000 dwellings the average period to secure planning approval is approximately 6 years, with a further of 0.8 years from approval to the first housing completion.

It is highly likely that the Local Plan will not be adopted until 2019 at the very earliest. If one assumed the plan was adopted at the beginning of 2019 and work progressed immediately on applications for these sites, the earliest realistic delivery would be 2026/27. This is well beyond the stated delivery assumptions in the table, some 5 years in the case of the Marston Vale Villages.

The other strategic sites at Arlesey and Biggleswade are smaller in scale and their delivery timescale is more realistic. Although in the case of Arlesey, delivery in 2023/24 is optimistic in light of the time that it is taking to bring forward the existing strategic allocation at Arlesey. That site was allocated in 2011 and no outline planning consent is in place as yet.

We would also query the soundness of the delivery table stating that Marston Vale Villages will deliver completions two years in advance of the Biggleswade and Arlesey allocations, which are smaller developments. There is no evidence provided to substantiate that premise.

In addition to delivery timescales, we would object/raise significant concerns with regard to the projected annual completions. In particular, it is stated that the Luton and Marston sites will deliver 300 dwellings each per annum The Nathaniel Lichfield Report analysed delivery rates and found that schemes of over 2000 units deliver on average less than 200 units per annum and that schemes of up to 1,499 units barely exceed 100 units.

In light of the above comments regarding delivery timescales and numbers we would suggest that the delivery numbers would be as per the attached table

Based on the figures, the strategic allocations would deliver a total of 5,960 new homes over the plan period. This is 3,940 dwellings less than projected in the Local Plan, leaving a major shortfall. Even if the delivery rate is not as low as these comments suggest, it is still contended that the Council's delivery rates are overly optimistic and a significant shortfall will arise. More sites need to be allocated to address this shortfall. The allocation of further sites will bolster supply and ensure choice and competition in the market. Inevitably there will be some sites that do not come forward. It is also important to state that housing targets in development plans are to be viewed as floors and not ceilings.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

7.1 Delivery Rates

Representation ID: 9047

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

STRATEGY - Over reliance on strategic allocations
DELIVERY - Delivery rates for some strategic allocations are optimistic, deliverability issues linked to viability, more small/medium sites should be allocated
NORTH LUTON - need to infrastructure, timescales for delivery ambitious
MARSTON VALE - timescales for delivery ambitious
EAST ARLESEY - impact of existing allocation on delivery

05

Full text:

GPS Estates Ltd are not convinced the Pre-Submission LP can deliver the high level of housing required during the plan period due to an overreliance on sizeable strategic allocations. This reliance would most likely lead to a failure to meet the housing target, particularly in the early years of the Plan. It is therefore imperative that the
Plan allocates a higher proportion of the housing requirement to small and medium sized sites, which are generally less complicated and quicker to deliver, to ensure that the substantial housing need is met throughout the Plan period.

It is acknowledged that strategic housing allocations have an important role to play in formulating and delivering a sound spatial strategy to deliver the growth required over the plan period. However, GPS Estates Ltd do not consider that the spatial strategy as currently detailed within the Plan will deliver that growth. In this respect the plan is not positively prepared or justified.

More specifically, it is our clear view that the strategic allocations will not deliver the numbers of dwellings that are set out in the table on Page 46 of the Plan. There are several areas of concern. Firstly, we believe that the trajectory makes optimistic assumptions on when sites will start to deliver housing. The strategic sites are all scheduled to start delivery by 2023/24 but the two largest sites, North Luton and Marston Vale, are stated as delivering as early as 2022/23 and 2021/22 respectively. This is considered to be optimistic.

The North Luton allocation has been identified as a strategic allocation for growth for some considerable time. It was identified with the Luton and South Central Bedfordshire Joint Core Strategy and the Development Strategy for Central Bedfordshire. Both of those plans were withdrawn and not proceeded with. However, this did not preclude the development coming forward. The North Houghton Regis urban extension was also included in those documents and subsequently planning applications came forward back in 2012. North Luton has never come forward as an application. A Framework Plan was approved by the Council in March 2015 for development management purposes. The Council states that a new Masterplan will be prepared.

It is expected that there will be deliverability issues linked to viability. There is some funding in place towards the cost of delivering the link road between the M1 and the A6 but the majority of the costs will be met by the developer(s). Notwithstanding this, the timescale for delivery by 2022/23 is clearly very ambitious.

The stated delivery timescale for Marston Vale Villages is even more ambitious than North Luton, with units expected to be delivered in 2021/22. This is just three years from the date of this consultation. As with North Luton, a Development Brief needs to be prepared and approved prior to planning applications coming forward.

Research has been undertaken within the construction industry to establish lead in times for large strategic sites to deliver housing on site. Nathaniel Lichfield and Partners published a report 'Start to Finish' in 2016. The research found for sites of over 2000 dwellings the average period to secure planning approval is approximately 6 years, with a further of 0.8 years from approval to the first housing completion.

It is highly likely that the Local Plan will not be adopted until 2019 at the very earliest. If one assumed the plan was adopted at the beginning of 2019 and work progressed immediately on applications for these sites, the earliest realistic delivery would be 2026/27. This is well beyond the stated delivery assumptions in the table, some 5 years in the case of the Marston Vale Villages.

The other strategic sites at Arlesey and Biggleswade are smaller in scale and their delivery timescale is more realistic. Although in the case of Arlesey, delivery in 2023/24 is optimistic in light of the time that it is taking to bring forward the existing strategic allocation at Arlesey. That site was allocated in 2011 and no outline planning consent is in place as yet.

We would also query the soundness of the delivery table stating that Marston Vale Villages will deliver completions two years in advance of the Biggleswade and Arlesey allocations, which are smaller developments. There is no evidence provided to substantiate that premise.

In addition to delivery timescales, we would object/raise significant concerns with regard to the projected annual completions. In particular, it is stated that the Luton and Marston sites will deliver 300 dwellings each per annum The Nathaniel Lichfield Report analysed delivery rates and found that schemes of over 2000 units deliver on average less than 200 units per annum and that schemes of up to 1,499 units barely exceed 100 units.

In light of the above comments regarding delivery timescales and numbers we would suggest that the delivery numbers would be as per the attached table

Based on the figures, the strategic allocations would deliver a total of 5,960 new homes over the plan period. This is 3,940 dwellings less than projected in the Local Plan, leaving a major shortfall. Even if the delivery rate is not as low as these comments suggest, it is still contended that the Council's delivery rates are overly optimistic and a significant shortfall will arise. More sites need to be allocated to address this shortfall. The allocation of further sites will bolster supply and ensure choice and competition in the market. Inevitably there will be some sites that do not come forward. It is also important to state that housing targets in development plans are to be viewed as floors and not ceilings.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SP7: Development within Settlement Envelopes

Representation ID: 9052

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

POLICY - inconsistent with NPPF. Too restrictive

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Full text:

This policy is considered to be inconsistent with the NPPF.

The NPPF seeks to boost the supply of housing and applies the presumption in favour of sustainable development. Policy SP7 seeks to restrict new development proposals on land outside of a defined settlement envelope. This policy does not allow decision makers to apply the presumption in favour of sustainable development. A site that lies outside of a defined settlement envelope, particularly those associates with larger settlements may be well placed to meet the definition of sustainable development as set out by the NPPF.

In addition, the policy states outside Settlement Envelopes the Council will work to maintain and enhance the intrinsic character and beauty of the countryside. The NPPF places a requirement on the decision make to recognise the intrinsic character and beauty of the countryside and supporting thriving rural communities within it. The policy seeks to 'maintain and enhance' which is not consistent with the NPPF.

The policy limits new development outside of Settlement Envelopes with the exception of inter alia dwellings for the essential needs of those employed in agriculture or forestry. Paragraph 55 of the NPPF advises LPA's to avoid 'isolated homes in the countryside' but includes a list of exceptions. Not all of these exceptions are included in Policy SP7. Furthermore, the NPPF does not specify the essential homes should be for agricultural employees or those employed in forestry it simply states the 'essential need for a rural worker to live permanently at or near their place of work in the countryside.

The restrictive nature of this policy requires very careful assessment of all reasonable and deliverable alternatives for development in and adjacent to settlements. To exclude land from development purely because it lies outside of a settlement envelope would place unnecessary limits on the most effective use of land and potential delivery of sustainable development. Policy SP7 is not justified, effective or consistent with national policy.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

11.1 Housing Mix

Representation ID: 9056

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

POLICY-does not conform with NPPF. Provides no clear guidance, too vague. Needs rewording.

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Full text:

GPS Estates Ltd support the process of underpinning the suggested housing mix in this policy with a robust evidence base, and concurs that an appropriate and inclusive housing mix contributes to well-designed places that produce strong community cohesion and cater for a diverse range of household needs.
Barton Le Clay in particular is a location that has been highlighted as requiring a diverse mix of housing, including some affordable housing, and, if possible, some single storey and assisted living dwellings for the elderly.
GPS Estates Ltd are however concerned that this policy will struggle to achieve the above as it does not conform with the requirements of the NPPF in paragraph 17 and 154 to ensure policies in the plan should provide a clear and practical framework with which decision making can be made with a high degree of predictability and efficiency. It provides no guidance as to what mix is deemed appropriate and whether this will be different for different sizes and types of residential development. In effect this policy requires an applicant to decide upon an appropriate mix from 8 different evidence base documents set out in paragraph 11.1.3. As such it provides no certainty as to whether the mix being put forward is acceptable, potentially leading to inconsistent decisions and unnecessary refusals.
Establishing a policy which effectively delivers housing mixes that reflect the bespoke needs in specific areas is particularly pertinent in rural settlements where, as the plan acknowledges at paragraph 11.5.2, there has been a chronic under allocation of affordable dwellings in rural areas. In general, however, there is a heightened need across the borough to respond to the prevailing requirements of specific localities in regards to housing mix and is crucial in alleviating the housing shortages currently experienced in the District. To be considered sound as well as achieving what it seeks to, this policy must provide clear guidance as to the required mix of housing in a range of localities and development types.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy H2: Housing Standards

Representation ID: 9058

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

POLICY-The proposed blanket rate of 35% delivery to this standard for all sites is deemed to be unsubstantiated, and upon reviewing the supporting text to this policy, GPS Estates Ltd are of the view that the Council are yet to do much of the necessary analysis to appropriately inform the requirements outlined in policy H2.

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Full text:

The position in this policy that some market homes must be provided to a higher access standard in order to provide choice within the market is supported by GPS Estates Ltd. However, the proposed blanket rate of 35% delivery to this standard for all sites is deemed to be unsubstantiated, and upon reviewing the supporting text to this policy, GPS Estates Ltd are of the view that the Council are yet to do much of the necessary analysis to appropriately inform the requirements outlined in policy H2.

Paragraph 56-007 of the PPG requires local authorities to demonstrate the need for the optional technical standards to be applied in new homes. This evidence should include the likely future housing need for older and disabled people, the accessibility and adaptability of existing stock, the different needs across tenure and the overall impact on viability. In evidencing their approach, the Council have simply stated that demand for more accessible dwellings is likely to increase in the future, however there is no analysis as to how many existing homes are accessible or the differing needs across different tenures. Therefore, to date, the council have not provided sufficient evidence, in line with the requirements of national policy, to substantiate a 35% rate of all new homes being built to the optional standardM4(2). Without conducting further research, it will be difficult for the Council to determine an appropriate level at which to set this requirement.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

11.3 Supporting an Ageing Population

Representation ID: 9061

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

POLICY-wording of this policy fails to explicitly outline the obligation of the applicant

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Full text:

GPS Estates Ltd support the provision of dwellings which meet the requirements of older people and maintain that delivering such dwellings is crucial considering the identified shortfall of these types of properties in the area. The wording of this policy fails to explicitly outline the obligation of the applicant in respect of expected rates of delivery for these types of dwellings therefore it conflicts with the requirements of paragraphs 17 and 154 of the NPPF to provide a clear and practical framework with which decisions can be made with a high degree of efficiency and consistency.

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