Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10438

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy HOU12 states that the Council will prepare a strategic place making framework to guide development across the policy area which will be adopted as a Supplementary Planning Document.
The six matters that Policy HOU12 intends to build upon in the SPD include:
a) Landscape, natural capital and green infrastructure;
b) Internal and external connectivity and active and low carbon travel;
c) Environmental regeneration and remediation;
d) Strategic master planning and placemaking principles;
e) Approaches to governance and stewardship of community assets; and,
f) Infrastructure delivery in accordance with the Council’s Infrastructure Delivery Plan.
National planning guidance (008 Reference ID: 61-008-20190315) states that “supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance
on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan.”
In the case of Policy HOU12, the six matters of focus for the SPD include landscape, connectivity, environmental regeneration, placemaking principles, governance and infrastructure delivery. These are all relatively broad topics that are already guided by the Borough’s general development management policies or separate strategy-making bodies in the area (e.g. Internal Drainage Board). Examples of such policies and strategies are provided below:
• Forest of Marston Vale (Policy 36S and SPD),
• Bedford to Milton Keynes Waterway Park (Policy AD27)
• Placemaking and Design Principles (Policies 28S and 29)
• Environmental Net Gain (Policy DM7)
• Green Infrastructure, Landscape Character, Landscaping in New Development (Policies 35S, 37 and 38)
• Minerals and Waste Restoration (Policy 48)
• Pollution, Disturbance and Contaminated Land (Policy 47S)
• Water Resources and Flood Risk (Policy 50S, 92)
• Resources and Climate Change (Policy DS1[S])
• Impact of transport on people, place and environment (Policy 88)
• Marston Vale Surface Water Plan (IDB)
There is potential here for the SPD to duplicate what is largely covered already in other policies or strategies governing the area but if more innovative or ambitious targets are sought, these should be presented upfront in Policy HOU12 to ensure they meet national planning policy requirements and are tested at examination stage. This is particularly important given the large number of potential development sites affected by this strategic place making framework.
The South of Bedford area covers a large area of the Borough including eight parishes. All of the site specific policies for this area require applications to be accompanied by design codes that accord with the proposed SPD. As the SPD covers such a significant area and number of sites, its preparation and adoption will likely be complex and time consuming. This could hold up several development sites, threatening not only the timely delivery of development but also a significant amount of the Borough’s housing supply and new infrastructure. To avoid this situation, we would recommend that any specific policy objectives and guidance for the South of Bedford be written into Policy HOU12 and not left to an SPD.

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