Greyfriars Development Brief SPD
2 Policy Context
This chapter of the SPD provides an overview of relevant national and local planning policy and guidance. With regard to local policy, the commentary summarises the adopted policy, but has due regard for emerging policy, which will have increased relevance during the lifetime of this SPD.
2.2 National Policy and Guidance
The National Planning Policy Framework 2021 (the 'NPPF') reflects primary legislation that states that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise. There is a general policy presumption in the NPPF in favour of sustainable development, although the development plan is the starting point for decision making. The 2021 NPPF places great emphasis on the design of high-quality places, partly through strong wording on the use of design guides, codes and design review panels, and enables councils to refuse permission for any development that does not in effect prioritise design quality or 'take the opportunities that are available for improving the character and quality of an area and the way it functions'. The NPPF also prioritises the ecological and landscape value of new developments and encourages opportunities for incorporating biodiversity improvements in and around developments, 'especially where this can secure measurable net gains for biodiversity'.
As part of the Government's collection of planning practice guidance, the National Design Guide was first published in October 2019 (and updated January 2021). The National Design Guide, as revised, sets out the characteristics of well-designed places and demonstrates what good design means in practice. Good design is explained in the Guide under 10 characteristics. These include (but are not limited to): context; built form; movement; nature; public spaces; resources (including a new direct reference to minimising carbon emissions to meet net zero by 2050); and lifespan. These characteristics encourage well-designed places that have compact forms of development that are walkable, contributing positively to wellbeing and placemaking. Well-designed neighbourhoods should include an integrated mix of tenures and housing types that reflect local housing need and market demand.
In parallel with the National Design Code, the Ministry of Housing, Communities and Local Government published the National Model Design Code in July 2021. This document provides detailed guidance on the production of design codes, guides and policies to promote successful design. It expands on the ten characteristics of good design set out in the National Design Guide and sets out a methodology and potential content for the Design Code. The revised National Design Guide and the final version of the National Model Design Code and accompanying guidance are material considerations in planning decisions and have been given significant consideration within the preparation of the Development Brief.
National Planning Practice Guidance (PPG) provides planning guidance on a range of topics, for example Environmental Impact Assessments, Healthy and Safe Communities, and Planning Obligations. Whilst the PPG should be considered throughout the planning process, the PPG should be used as guidance, and not be seen as representing formal Government policy.
2.3 Relevant Policy
The policy that applies to the SPD area is set out in the adopted Development Plan, which includes:
Bedford Borough Local Plan 2030 (2020). This document is the overarching development plan document which outlines Bedford Borough's growth needs to 2030. The Local Plan primarily focussed on identifying the most sustainable sites to provide new housing to meet the needs of the community. Development will be focussed towards brownfield sites, which will include minimising impacts on biodiversity and creating a robust green infrastructure network. These measures will help to improve the quality of life for residents, and combined with visitors to the area, will increase the borough's attractiveness as a place to live, work and visit.
- The Greyfriars SPD site is not allocated for development in the adopted Local Plan (note the adjacent police station site is allocated for mixed use development (Policy 11)). However, Policy 3S outlines the spatial strategy for the borough, which makes clear that new retail, leisure and office development should be focussed in Bedford town centre, and that new areas for vibrant urban living should be created in Bedford's urban core.
- Policy 46s states that the Council will seek to maximise the delivery of development through the reuse of suitably located previously developed land.
- Other relevant adopted policies cover non- residential uses (policies 69S; 74; 77S; and 98); Policy 45 - Local Open Green Space; Policy 58S – Affordable Housing; Policy 59S – Housing Mix; Green Infrastructure and Biodiversity (policies 35S, 38, 39, 42S and 43); Energy and Sustainability (policies 51S, 54 and 55); and historic environment – Policy 41S.
- Other, policies relevant to the Greyfriars SPD site include: Policy AD28 Provision of Open Space in Association with New Development; Policy AD36 Pedestrian Routes; Policy AD39 Cycling; and Policy AD43 Urban Open Spaces and Gaps.
2.4 Material Considerations and other policy
Emerging Local Plan
The Council began looking at issues and options, undertook a call for sites, and have now drafted the 'Local Plan 2040: Plan for Submission'. This was consulted upon in June and July 2022, and will undergo Examination in Public before adoption.
Draft Policy HOU1: Land at Greyfriars North covers this site, and proposes to allocate the site for residential and appropriate town centre uses . The policy requires:
"A masterplan and design code to be prepared and adopted as a Supplementary Planning Document prior to the submission of any planning application for the site. The preparation of the Supplementary Planning Document will be led by the Council in partnership with landowners / developers, stakeholders and the local community. It should pay particular regard to ensuring that the development is designed to reflect the site's important location and to preserve the setting of heritage assets, including The Bedford Conservation Area, listed buildings fronting Bromham Road and other taller heritage assets in the town centre".
Additionally the development should have due regard for: appropriate access; improved pedestrian/cycle connectivity; contributions to town centre highway infrastructure and secondary school provision; archaeological evaluation; and delivery of low carbon and environmentally resilient development.
Other notable draft policies include: tall buildings (policy DM12); environmental net gain (policy DM7); residential space standards (policy DM6); and non- designated heritage assets (policy DM10), which will all inform the future development of the site.[KE1]
Bedford Borough Design Guide Settlements and Streets (March 2023).
The Council have recently adopted their borough-wide design guide. This provides general design advice for future development in the borough, offering a source- book of landscape and residential built environment qualities and characteristics that must inform early- stage design principles in new development. The 16 design principles have heavily influenced the layout, building form and details of the SPD (and analysed further in section 5).
- Open Space SPD (2013)
- Sustainable Drainage System SPD (2018)
- Bedfordshire Community Safety Design Guide SPD (2005)
- Planning Obligations SPD (2013)
- Parking Standards for Sustainable Communities SPD (2014)
Other relevant plans and strategies
- Bedford Town Centre Plan 2020-2023. This outlines a series of initiatives to boost Bedford Town Centre's activity and reputation. This includes freezing parking charges; the redevelopment of the bus station; the announcement of a 'Town Centre Priority Fund'; Homelessness Reduction Initiatives; and the Townscape Heritage Initiative; among others.
- Bedford Central Town Masterplan Plan Report (2018).Bedford Borough Council commissioned the study to investigate how public assets could be used more effectively to benefit local people and deliver new homes. This formed part of the Local Plan evidence base, and provides a framework of short term environmental improvements, as well as opportunities for longer term residential development. The study focussed on the south and west of the town centre, and most notably for the Greyfriars SPD area includes the Police Station site and the site to the south of this, on the west side of Greyfriars road.
- Bedford Borough Council's Declaration of the Climate Emergency (March 2019);
- Bedford Borough Local Transport Plan 2011-2021. This document sets out the transport aims and ambitions for Bedford Borough and identifies the key strategies, schemes and initiatives necessary to deliver corporate and local outcomes.
- Bedford Town Deal. A series of economic and regeneration initiatives are currently being consulted on by BBC. These include the regeneration of the Station Quarter and Midland Road area, as well as improvements to local junctions and cycling and pedestrian infrastructure across the town centre. These adjacent improvements will also enhance the SPD area. It should be noted that the SPD proposals have been developed to tie in with the Bedford Town Deal improvements. However, the other improvements designed into the Greyfriars masterplan (this SPD) sit outside of the Bedford Town Deal junction improvements.
N.B. Whilst it is acknowledged that the main road is known as "Greyfriars", in the case of this document to avoid confusion, the term "Greyfriars" refers to the area, and "Greyfriars road" has been used to refer to the road.