Issues and Options

Yes

Bedfordia Property Response: 1.1 We agree that the Local Plan Review should propose to develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements. This will require sufficient amount and variety of land to come forward where it is needed to meet housing, economic and community needs. As part of that process, there should be a review of both the development management policies and land designations set out in the Local Plan 2030 and those saved from the ‘Allocations and Designations Local Plan 2013’ to ensure land is not unreasonably restricted in sustainable locations that would otherwise make a positive contribution to the Borough’s growth needs. 1.2 Housing needs, in particular, are set to rise with the Standard Method setting a minimum requirement of 5,550 additional homes over the next 15 year plan period. This warrants a review of current land designations as well as identification of new development sites. It should also be borne in mind that the needs of the local community are not static in time and should be consulted on and reviewed in terms of the local planning authority’s requirement to set out non-strategic policies for specific areas, neighbourhoods or types of development, as guided by paragraph 28 of the NPPF 2019. 1.3 Saved Policy AD43 (Urban Open Spaces and Gaps) of the Allocations and Designations Local Plan is now seven years old and aims to protect urban open spaces in Bedford that maintain the function, character and identity of the urban area. Development will not be permitted on these land designations unless it can be demonstrated that the reasons for designation are not compromised or that other material considerations outweigh the need to retain the urban open space and undeveloped gaps. 1.4 The urban open space identified north of Cemetery Road and west of Kempston Hammers Sports and Social Club was surveyed in 2010, as part of the ‘Review of Urban Open Space’ background paper and was not previously designated. Its reason for designation is due to its contribution as a visual break, which allows views across the open space to the north of the site. The site, however, is privately-owned and not formally designated as a public open space. Its contribution as a ‘visual break’ is incidental and not based on a robust and up-to-date assessment of the need for open space. The site is also not devoid of all development: adjacent to Cemetery Road is a foul water pumping station and the residential dwelling known as Walnut Tree Cottage. Both of these developments partly obscure views to the north along with existing boundary hedging. 1.5 We would therefore question the consistency of this urban open space designation with the NPPF’s paragraph 96, which states that planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses). This is pertinent given the site’s lack of formal public use over time and the close proximity of open space and sports to the east. Instead, we think the site should be allocated for development of much needed housing and community facilities. Such development would be in a very sustainable location, close to the existing community and of a scale that would make a meaningful contribution to the local area. 1.6 Such a proposal has been put forward by Bedfordia Property in the recent Call for Sites consultation and includes development of a community centre with accompanying residential development to help cross fund the centre. Land opportunity within Kempston for community uses is limited and demand for such facilities is expected to grow with an increasing population. Existing facilities such as the Addison Centre are outdated and constrained in their location, unable to expand sufficiently to meet larger community group needs. 1.7 Provision of new indoor community facilities to meet local needs is a topic that requires more focus in the Local Plan review and should not simply rely on development management policies (e.g. Policy 98) but a more proactive strategy for allocating new sites and sufficient land for indoor community provision, especially where existing community facilities are constrained and unable to meet the growing population’s needs. This would follow the NPPF (paragraph 92) objective for planning policies and decisions to plan positively for the provision and use of shared spaces, community facilities and other local services to enhance the sustainability of communities and residential environments taking into account local strategies to improve health, social and cultural well-being for all sections of the community. 1.8 Indoor and outdoor community space provision go hand-in-hand, with multiple social, health and wellbeing benefits. The submitted site at Cemetery Road, Kempston provides a suitable location for this complementary provision, along with supporting residential development, which should not be held back by artificial constraints, such as the historic Urban Open Space policy. This is not to say that the aims and objectives of such designations should be ignored, especially where there is scope to accommodate some open space within the site, which can be enhanced, along with the retention of key views, enhancement of biodiversity and protection of designated heritage assets. We believe the submitted site at Kempston has scope to achieve these objectives and should be reconsidered in terms of its purpose and designation in order to provide wider public benefits.