Representations to the Pre-submission Draft Central Bedfordshire Local Plan Regulation 19 Consultation February 2018 Submitted on behalf of: Marston’s Inns and Taverns Representations to Draft Central Bedfordshire Local Plan 1. Introduction 1.1 Cerda Planning Limited has been instructed by Catesby Estates Plc in response to the pre-submission draft local plan consultation to promote land to the north of New Walk, Shillington for allocation as a site for housing within the local plan. 1.2 The site is approximately 5.47 hectares in size and is accessed directly off New Walk from Hillfoot Road to the west and High Road to the east. 1.3 The site is under the control of a single landowner and is suitable, available and achievable to be brought forward within a five-year period and as such could make a meaningful contribution to the delivery of the housing targets as set out within the draft plan. It is likely that the site would be to accommodate between 70 and 80 dwellings depending on the detailed housing mix and density of the scheme. 1.4 This document should be read in conjunction with the site location plan, Vision Framework prepared by Catesby Estates Plc and the Review of Housing Need and Land Supply prepared by Lichfield’s. Page 2 Marston’s Inns and Taverns Representations to Draft Central Bedfordshire Local Plan 2. Growth Strategy and Housing Requirement 2.1 Paragraph 157 of the NPPF sets out that local plans should be positively prepared and meet the objectively assessed needs for the area and accord with the objectives, policies and principles of the Framework. 2.2 The Plan target is to deliver 39,350 homes over the period 2015 - 2035. This figure is comprised of Central Bedfordshire’s objectively assessed housing need over this period (32,000 homes) with the addition of Luton’s residual unmet housing need (7350 homes). This leads to a requirement of 15,405 dwellings to be allocated through the local plan with a reliance on a significant windfall allowance of 2,897 dwellings. The 2017 SHMA for Luton and Central Bedfordshire established that there is an annual need for 1,600 dwellings per annum. 2.3 The Council is required to ensure that the local plan meets the full, objectively assessed need for both market and affordable housing over the plan period in the housing market area. It is likely that the new standardised methodology as set out by the government in the Housing White Paper will be applicable to the calculation of the OAN for Central Bedfordshire. The present indication as set out by the Government is that the need in Central Bedfordshire would be 2,553 dwellings per annum, significantly higher than the position as set out in the SHMA. This indicates that the housing requirement would need to be increased significantly in order to ensure that the OAN is effectively planned to be met and this is likely to result in a degree of flexibility be required through the local plan to accommodate the basis of a higher level of need and to ensure that the council is able to maintain a 5 year supply of deliverable housing land. 2.4 As set out in the Review of Housing Need and Land Supply by Lichfield’s the OAN could be 51,000 dwellings over 20 years which excludes the likely unmet need arising from Luton of around 20,000 dwellings. This increased unmet need would likely need to be met in Central Bedfordshire as this forms a close part of Luton’s HMA. Therefore the total requirement for Central Bedfordshire could be a minimum of 70,000 dwellings over 20 years, almost double the target as set out in the plan. Page 3 Marston’s Inns and Taverns Representations to Draft Central Bedfordshire Local Plan 2.5 Furthermore, as Lichfield’s set out, the target of 39,350 dwellings proposed in the plan is lower than the levels tested at the Regulation 18 stage of 44,505 and 54,354. It is not clear why such a reduction is now proposed at the Regulation 19 stage when it would appear that this level of growth has not been tested robustly through the Sustainability Appraisal process. As such all reasonable alternatives for growth levels which underpins the spatial strategy as set out in Policy SP1 have not been considered in-line with national policy. No justification has therefore been set out to evidence the approach taken towards the lower strategy of growth. 2.6 Whilst the draft local plan recognises that an early review will be required, even as soon as 6 months post adoption, it is clear that further sites are required to be allocated at this stage in order to ensure that the local plan is planned positively and based on adequate, up- to-date and relevant evidence and take into account relevant market and economic signals as per paragraph 158 of the NPPF. 2.7 Paragraph 153 of the NPPF allows for a local plan to be reviewed in whole or in part to respond flexibly to changing circumstances. The inevitable increase in the OAN is a known pressure and needs to be planned for now as a result. Planning for this increase at this stage, either through additional allocations or identifying reserve sites will allow for the plan to respond quickly to the changing circumstances, without the need to go through further consultation. This approach would also provide for a more flexible Plan, thus being better able to deal with unforeseen circumstances such as better economic and employment growth or a dip in the housing trajectory. 2.8 It is also considered that the approach taken is not helped by the significant reliance placed on windfall sites coming forward as opposed to proactively planning for and allocating additional housing sites at this stage within the plan process. 2.9 One of the potential major weaknesses with the strategic distribution of growth as set out within the draft local plan is the significant reliance on four major strategic sites for the delivery of the bulk of the housing requirement. Neither of the four sites at North Luton, Marston Vale, East of Arlesey and East of Biggleswade Page 4 Marston’s Inns and Taverns Representations to Draft Central Bedfordshire Local Plan are projected to start delivering more than 50 units per annum until 2022/2023. Highly optimistic delivery rates are projected in the region of 150 to 300 units per annum in years 2023/2034 up until the end of the plan period in 2034/2035. In the present state of the housing market, which is not projected to alter in the short to medium term given the state of the wider economy and Brexit uncertainty, it is highly unlikely that any volume house builder would be able to deliver 300 units per annum off one single site whether either alone or with a consortium of others. It is also considered that with 2,600 dwellings projected to be delivered from three of the four strategic allocations post the end of the plan period that further smaller and medium sites need to be brought forward in the short to medium term as part of the plan to ensure that the overall target and requirement can be met as there is a clear risk that further dwellings from the large strategic sites are likely to fall off the back of the plan period. 2.10 This scenario has been faced by other local authorities that have planned heavily on the reliance of large strategic allocations and SUEs for the delivery of the bulk of their housing numbers. Hinckley and Bosworth, Leicestershire planned to deliver two SUEs at the adoption of their plan in 2009 (a total of 3,500 dwellings) and to-date not a single dwelling has been brought forward due to the infrastructure and viability challenges faced. The same scenario occurred more recently in Charnwood, Leicestershire where the authority most recently adopted its local plan in 2015 and is since unable to maintain a five year supply of housing land due to the failure of three strategic SUE’s to deliver the numbers of dwellings originally projected. Whilst these are two specific examples there are significant numbers of other strategic housing allocations across the country that have failed to deliver the numbers of dwellings that were originally envisaged when the plan was prepared due to the challenges around infrastructure, achieving multiple land owner agreement, the state of the housing market and viability. 2.11 The need to address and deliver the backlog in the shortfall of housing supply within the first five years of the plan is positive. However, it is only reasonable to assume that this backlog will actually be delivered if Page 5 Marston’s Inns and Taverns Representations to Draft Central Bedfordshire Local Plan further smaller and medium sites are allocated and are readily deliverable within the five year period. 2.12 Otherwise given the dependency on strategic sites over the life of the plan to deliver the significant majority of the housing requirement there is a risk that the backlog would not be cleared within the first five years in accordance with the NPPG. 2.13 A significant contingency should be allowed within the site allocation process to ensure that there is sufficient flexibility to ensure that the Council can respond positively to changes within the trajectory when the plan is implemented. Further allocation of smaller and medium sites that are able to deliver units rapidly within the five year period should be considered suitable for allocation in conjunction with the longer term strategic allocations to ensure that a balanced approach is taken towards meeting the overall housing need across Central Bedfordshire.