Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10001

Received: 29/07/2022

Respondent: Dr Margaret Turner

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The Plan is not sound in that it fails to take into consideration Bedford Borough 2010 Character Appraisal and Management Plan.
The northern part of the proposed control of development area falls within the Elstow Conservation Area, as outlined in the BBC 2010 Character Appraisal & Management Plan (CAMP) and considered at this time to be “of special interest”.
In Policy BE9 of the CAMP, The Council undertook to “protect the character and Appearance of the conservation areas through the careful control of development “. HOU5 of The Local Plan 2040 fails to demonstrate this.
In Policy BE11 Bedford Council undertook “to ensure all new developments within, adjoining or likely to affect the setting of conservation areas, preserves or enhances its character or appearance. This has not been explicit or even sufficiently allowed for under the 2040 Local Plan, in terms of scale, form, likely density, levels of traffic generation, the visual impact or other environmental controls.
Under BE 15 BBC undertakes to “protect important views in conservation areas and refuse development on any open space which contributes to the inherent character of the area”. The open space and view across to the Abbey church should fall under this definition.
Policy BE23 protects archaeological sites and so it should be necessary to further survey and record the important archaeology
The case for the proposed development to bring about benefits in terms of economic regeneration and/or environmental enhancement has not been made.
In relation to the Duty to co-operate, the plan falls short in relation to that part of the duty which requires co-operation with statutory bodies to address climate change, including the
management of flood risk and the provision of open space and most particularly the protection of known sites of archaeological and historic interest and the open views of these important sites.