Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10309

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Our client supports with reservations the Council’s proposed update to Policy 75 of the adopted Local Plan 2030 and the policy objective to improve opportunities for new employment in the countryside.

This representation addresses our client’s interests that were submitted and the subject of comments at previous consultation stages:

• Land at Rushden Road, Milton Ernest (Site ID: 852) – supporting the intensification and enhancement of existing commercial floorspace
• Land at Highfield Road, Oakley (Site ID: 1000) – providing opportunities for economic development and jobs growth adjacent existing employment provision

In both cases our client’s interests would be supported by the proposed criterion in Policy DM8 to enable the enlargement of existing employment areas. Our client would endorse that these provisions are necessary for consistency with national policy to support a prosperous rural economy and to allow all settlements to grow and thrive. This was advocated as part of our client’s previous submissions, noting in-particular the distribution of land for economic development across Key Service Centre and Rural Service Centre locations to the north of the borough (including at these two locations) and the reasons to support housing and employment growth at these centres within the settlement hierarchy.

Notwithstanding this, we have reservations regarding the soundness of the proposed approach in terms of the effectiveness of the policy, specifically in relation to the definition of enlargement of existing employment areas. This is considered to be overly restrictive and potentially imprecise in terms of the opportunities the policy would support. The supporting text to the policy does not explain whether this approach would support development outside of existing settlement policy area boundaries or the circumstances where this would be appropriate.
For example, our client’s land at Highfield Road operates on a tightly defined site enclosed by existing road boundaries. However, land to the south and west is functionally well-related to the successful existing facilities and functionally-related to the adjoining settlement at Oakley and thus would represent a suitable location for economic development in accordance with the objectives of the policy and wider strategy.

Therefore, as drafted we consider that Policy DM8 is unsound as it is not effective, but is capable of Modifications as described below.