Policy TC2

Object

Representation ID: 3643

Received: 16/08/2021

Respondent: Great Barford Neighbourhood Plan Group

TC2 Limiting out of centre retail and leisure development and applying conditions will not encourage development towards the town centre, it will drive it away to build outside the borough and take trade away from Bedford.

Object

Representation ID: 3688

Received: 19/08/2021

Respondent: GB PC

TC2 implies out of centre retail and leisure development may be by exception with conditions applied. This could put off development in a misguided attempt to try to attract development to town centre. Unless vehicular access to town centre development is made a priority, then significant development will go to where easy (free) parking is guaranteed. See comment at 5.7

Support

Representation ID: 3825

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC supports the policy as drafted.

Support

Representation ID: 4656

Received: 01/09/2021

Respondent: Mr Denis Ivins

support this

Object

Representation ID: 5341

Received: 03/09/2021

Respondent: Mrs Clare Buddle

The different locations should be differentiated in separate paragraphs: if they are all together they appear to roll into one and thus all seem achievable, contrary to the government’s clear town centre first strategy and the borough’s ongoing work to improve the town centre.

“These should preferably be ”… should be changed to “These must be…” to boost sustainability and reduce car reliance.

The sentence “Certain uses that have…” must be omitted as it encourages inappropriate, unsustainable applications.

Object

Representation ID: 5343

Received: 03/09/2021

Respondent: Mrs Clare Buddle

“Any retail and leisure development proposed outside of the defined town centres must be subject to an impact assessment if it exceeds the following thresholds.” must be changed to “Any retail and leisure development proposed outside of the defined town centres must be thoroughly justified and will be subject to both sequential and impact assessment if it exceeds the following thresholds."

Support

Representation ID: 5380

Received: 03/09/2021

Respondent: Ms Jackie Brand

I agree with policy TC2: Only if suitable sites are not available in the town centre and district centre, should out of centre sites be considered.
However, to support this policy, rents need to be attractive for businesses to set up and stay in the centre. Section 4.16 of The Bedford Town Centre study commented “However, in Bedford,....., with a greater proportion of vacant units, and certainly vacant floorspace, in its core. This is perhaps indicative of retail rents being more affordable for start-up businesses on the edges of the Town Centre, as opposed to in its central areas.”

Object

Representation ID: 6363

Received: 13/09/2021

Respondent: Mr John Orchard

Whilst I am writing this response as a local resident, I cannot ignore that I have been a retail manager for nearly fifty years, in town centre management for thirty five years and am a trained and practicing geographer with the distinction of being one of a very small number that has carried out primary research into the real impact of business rates in town centres and less exclusively, town centre dynamics.

The policy(ies) are certainly in line with the NPPF and intentions of the government. However, I have been continuously critical of the background to the NPPF policies since they are, in my opinion, fundamentally flawed.

The policies and the language employed is all about the town centre being a retail space. I agree that that is how they have become, but that Is due to the culmination of policy (Town and Country Planning Act, 1947 (and subsequent Acts); Abolition of Resale Price Maintenance (1964) (and the precursor measures in the 1940s and 50s); and the resulting changes to the retail paradigm, land ownership and developing strength of specific vested interests including corporate retailers and professional planning bodies.

Retailing will thrive in places where there is a sufficient number of people with a disposable income, however, the retailers will identify the best sites based on their own business plans and models – these are not always in synch with thinking in planning departments.

The language employed now that we are into the third decade of the current debate on the state of the high street speaks of mixed use. The very thing that high streets were until 1964 and the change of the retail paradigm – which was then taken up by the planning professionals to produce separate zones of activity in our towns.

This policy seems to be enhancing the Town Centre First policy of the NPPF, but since that has a very chequered history in terms of its application, it is important that these policies are adhered to in a fair and equitable manner and not varied solely on the basis that a particular retailer dislikes it. Corporate retailers have no loyalty to any location and to build towns around their perceived needs is fraught with problems.

Over the past fifteen years one of my main functions has been to work as a consultant to the administrators of large corporate retail businesses in administration. Looking after large groups of stores and their staff during the really difficult periods in which they are under threat of job loss has focused my attention on the downsides of reliance on retailing as a basis for planning, and it has certainly eradicated any ideas that I ever had of seeing retailing as the basis of regeneration.

Our policies ought to reflect the mix of use, and local authority weight needs to be behind the identification by the people of what role their town centre should have. In the town in which I moved to in 1961 the main street was populated largely by shops, but also with some residential, and a large dose of other stuff, such as public halls, theatres, pubs, cinemas, banks professional advisers and the retail offer was a real mix of corporate brands and locally owned businesses.
The 1964 paradigm shift in retailing resulted in the marginalization in many towns of any other activity than retailing by the main brands. The subsequent movement towards out of town or edge of town sites created new and well-received retailing spaces, but in the absence of policy or effort by planners, the traditional sites started to see increasing numbers of voids.

The regeneration of any town can only be achieved by a series of separate but economically linked activities:

1) The establishment of high level wealth creating activity. Contrary to many reports, retailing does not create wealth it merely moves capital around, very often away from the town concerned.
2) The informed and joined up approach to land valuations, and the positive influence of the local authority on the valuations of town centre properties to effectively reflect the state of their situation.
3) The acceptance that there is too much retail sales floor space and that any new opening anywhere in the catchment will have an impact on existing stores.
4) That the current planning determinants by classes is no longer fit for purpose and works against the process of encouraging mixed use.
5) That business only consultations or business only improvement districts are restrictive and likely to provide flawed plans.

Bedford is a town that evolved throughout the medieval period. It did so without the need for positive planning. Instead it relied on markets being driven by demand and responding. It is a place that has an enormous potential given its architectural, cultural and topographical advantages.

The wholly predictable demise of all of the departments stores in the town offers opportunities, but also attendant threats. The Nexus report, which itself speaks loudly of the retail role and the rise and fall of certain brands in the town says nothing about how retailing will thrive without the overarching economic activity that was once provided by industrial activity or similar. That is a serious flaw in the report which is in any case already out of date. It is dangerous to base policy on flawed and outdated data.

Support

Representation ID: 7174

Received: 17/09/2021

Respondent: EF Wootton and Son

Agent: Phillips Planning Services

The policy should recognise the opportunities of certain areas including the Bedford River Valley for leisure and recreation uses, which will inevitably include “town centre uses”. We would therefore recommend that an exception to the policy or a criteria be added to the policy, that can allow delivery of the vision for the Bedford River Valley.

Support

Representation ID: 7936

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council provided its comments on the Town Centre and retail policies at the time of the Borough Council’s last consultation. Those comments do not need to be reiterated at this juncture save to say that the Parish Council welcomes the Borough Council’s recognition that the Strategic Centre, i.e. Bedford Town, is in urgent need of regeneration and support. Out of town retail, the pandemic and on-line shopping have reduced Bedford Town centre to a shell of its former self and it is queried whether its character as a retail centre can ever be fully restored.
On that basis, the Parish Council would welcome any initiative which would render the town centre safe and pleasant and it does re-iterate that regeneration in the form of residential/hotel provision would offer a positive way forward.
The Parish Council would certainly support a “town centre first” approach as advocated by the NPPF.
In this context, in relation to proposed draft Policy TC2, the Parish Council would express some concern with regard to any policy that promotes new out of centre retail development and would support the conditionality requirements and thresholds. In addition, a shift back from out-of-town retail to town centre retail would be much more environmentally sustainable with more people able to walk and use public transport to access shops, etc.

Support

Representation ID: 8514

Received: 02/09/2021

Respondent: Bedfordshire Police

Whilst we support the provisions in Policies TC2, TC5 and TC9 that state proposals in town centres
should not lead to anti-social behaviour or other problems, the issue of the night-time economy would
be better addressed through a dedicated policy on the topic due to the complex issues involved. We
propose the following for inclusion in the Local Plan:
Policy TC?? – Evening and Night-time Economy Development
Developments that will deliver a safe and socially responsible evening and night-time economy in
the Borough’s town centres will be encouraged. A balanced mix of uses will be supported including
late-night shopping, theatres, cinemas, galleries, museums, cultural activities, cafes, restaurants,
bars and clubs.
No development must, individually or cumulatively, create an unacceptable impact on neighbouring
uses or the surrounding area by reasons of noise pollution, light pollution, anti-social behaviour,
crime, disturbance, traffic, littering or other side effects.
Developments associated with the evening and night-time economy should also seek to ensure
activity during the daytime where possible to avoid the clustering of ‘dead’ frontages.
5
Proposals linked to the evening and night-time economy will be expected to contribute towards
public realm enhancements, infrastructure improvements and emergency services provision in
order to ensure safety and security. Contributions towards public transport, toilet facilities and CCTV
for the benefit of the evening and night-time economy will also be encouraged.
Owners and operators of evening and night-time economy development will be expected to take
part in active management measures to help the public and emergency services in partnership with
the Council and other stakeholders.
Planning decisions will include conditions and legal agreements to deliver the above and secure
closing times where appropriate.
Including the above policy in the new Local Plan will ensure that this type of development is located in
appropriate places in the Borough. At the same time it will guarantee that the well-documented
negative side-effects of this type of development will be carefully controlled and mitigated to the
maximum possible extent.
The proposed policy also establishes a solid basis upon which public sector agencies, private companies
and other stakeholders will work together to coordinate the active management of this type of
development in the town centres.
In the experience of BP and other Forces around the nation, if this type of good quality planning policy
is not implemented, then delivery of evening and night-time economy development will simply equate
to a rapid rise in crime and antisocial behaviour levels in direct proportion to the scheme(s) being
delivered. An outcome nobody wants.

Object

Representation ID: 8911

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy TC2 (Out of centre development) – Comment
2.1 The policy sets out that new retail, leisure, and office development is required to locate in Bedford town centre, Kempston district centre and the local centres as defined in Policy TC1S – Hierarchy of town centres. If no suitable sites are available, edge of centre locations should be considered and only if suitable sites are not available should out of centre sites be considered. Principally we support Policy TC2 in terms of its support for out-of-centre development subject to an assessment of potential impacts. However, in terms of the opportunities and development of tourism and leisure uses required to achieve the Council’s Vision and Objectives the policy fails to provide sufficient flexibility in terms of how these should be assessed for the purposes of decision-taking or achieved as part of the wider strategy.
2.2 In terms of opportunities for rural tourism and recreation including the creation of green infrastructure, these aims should be secured through the allocation of our client’s strategic opportunity at Radwell Lakes.
2.3 Should the land not be selected for allocation Policy TC2 should be modified to introduce exceptions for retail and leisure development in order to provide support for development (such as rural tourism and recreation) that is not compatible with Town Centre locations but would complement the Plan’s wider strategy.
2.4 This exception should be provided subject to suitably worded policy criteria (such as arrangements for access and controls over future use) to ensure no adverse impact on Town Centre locations. Such criteria could be satisfied in the case of our client’s land at Radwell Lakes while also enhancing the benefits of other village-related growth.
2.5 This is necessary in order to provide flexibility so that the Local Plan can respond quickly to a changing commercial market.