Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10502

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Hallam Land Management objects to the proposed Policy for Essential local shops and public houses and their change of use.

The approach is not consistent with national policy (see paragraph. 93 c)) and no specific justification for it, that is consistent with national policy, is provided. Equally, what constitutes an essential service or facility is also not explained nor easily done – which types of shops – foodstore, nailbar etc. If the policy is to preclude a congregation of hot food or similar retail elements, then it should say that.

In the absence of the justifications set out above, Hallam suggest that the policy is deleted and not pursued.

Were the policy to be retained, Hallam considers that the requirements of ii) should only apply to be consistent with paragraph 5.27 if there are no alternative facilities, with regard to i), within 1,000 metres or that a broad range of facilities is available. We believe the requirements for ii) should only apply when i) cannot be met. Otherwise, Hallam considers the requirements of ii) would be too onerous if alternative essential services are available within the 1,000 metres distance threshold. That definition should also be widened to address the breath of services in communities rather than simply distance which is arbitrary.

Hallam also considers criterion iii) to be vague in terms of ‘similar uses’ and would welcome clarity on this term. Without such clarification the objective of iii), appears to overlap with the objectives of Policy TC9 which seeks to guard against the impacts of concentrating similar, albeit “Town centre uses”. Hallam in this context questions whether iii) is necessary. Should it be so, then Hallam would also request the criterion to clarify that test it to be applied to the proposed use.

Equally even if uses are viable, there are planning and other justifications, that would permit alternative uses or purposes and the loss of such a facility as a result of wider benefits achieved. This should be recognised in any policy.

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