4.41

Object

Representation ID: 10313

Received: 29/07/2022

Respondent: Castlecap Investments Ltd

Agent: Lichfields

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Introduction
Our client, Castlecap Investments Limited (“Castlecap”), owns the Greyfriars site in Bedford town centre. Castlecap is in dialogue with Bedford Borough Council (“BBC”) regarding their future aspirations for the site.
Castlecap supports the Local Plan 2040 and the vision and objectives set out in the ‘Plan for Submission’ version. In particular, Castlecap supports Policy DS2(S) and its aim to maintain and enhance Bedford town centre “as a vibrant and resilient location and multifunctional destination…regenerating vacant spaces” and establishing “town centre living at Greyfriars”.
This letter sets out comments on behalf of Castlecap, which relate to the soundness of the Plan for Submission version.

Greyfriars site policy
Castlecap’s landholding is subject to Policy 11 within BBC’s adopted Local Plan 2030. The Local Plan 2040 proposes to ‘save’ Policy 11.
Castlecap considers that it is unsound (not positively prepared or justified) for there to be no new policy for the Greyfriars site in the Local Plan 2040. Given other town centre site allocations being proposed as part of the emerging Plan, it is not consistent that the policy for Greyfriars is not being updated to reflect the latest position. The latest position includes the current application for the Police Station site, which forms part of the allocated site and has a resolution to grant planning permission.
One of the uses that Castlecap is considering for the site is Build to Rent (“BTR”) housing units, as part
of a mixed use development. In this context we note that text within the Local Plan 2040 on two other sites (South of the River/Bedford St Johns Station and Ford End Road) refers to opportunities for BTR, confirming that BBC supports this type of housing in appropriate locations. BTR is an appropriate use for town centre sites and can improve the range and type of accommodation available in the private rented sector. The policy should also reflect that BTR units do not require the same level of car parking provision as typical residential developments.