Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9958

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and L & Q Estates Ltd

Agent: Barton Willmore

The promoters continue to support the
premise of the policy and welcome the ‘by negotiation’ position on larger sites. However,
as raised in our Regulation 18 Consultation representations, the policy still does not
provide guidance on how these should be dealt with, when larger sites require the
submission of a Design Code. A clearer mechanism should be inserted into the policy
which outlines how this may be dealt with i.e. a self-build ‘passport’ scheme. There is
always a danger of gaps in the streetscene, or unfinished properties, by including selfbuild
plots into development proposals and this needs to be avoided to ensure cohesive
and consistent developments.
We would request further explanation of how specific percentages required by different
scales of development have been arrived at. For example, a requirement of 2no. self and
custom build plots on a 10-dwelling site equates to 20% provision, and a requirement of
7no. self and custom build plots on a 90-dwelling site equates to approximately 8%
provision. Typically, many local plans require roughly 5% provision or are negotiated on
a case-by-case basis according to evidence of need. This also represents an imbalance in
how much provision is sought based on the scale of a site, when there is no evidence to
support such an approach.

Comment

Representation ID: 9959

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and L & Q Estates Ltd

Agent: Barton Willmore

The principle of seeking biodiversity net gain is
supported. We welcome flexibility in the wording of this policy which reflects the ability
to provide net gain offsite should it not be possible on site. The policy should be further
updated for the purchase of biodiversity net gain credits as a ‘last resort’, the conditions
for which should be defined. This would be consistent with the Environmental Bill.
As raised in our Regulation 18 consultation representations, the policy in the blue box
focuses primarily upon biodiversity net gain. However, it requires the following:
“Planning applications should demonstrate how net
biodiversity and net environmental gain will be achieved
through the product ion of a supporting statement that considers the contribution the proposal could make to the
borough ’s natural capital.”
In the pretext to the policy under point 6.62, the following sum example is provided:
Environment a l net gain = biodiversity net g in + natural capital gain
This appears inconsistent with the policy which suggests the approach is: environmental
net gain + biodiversity net gain = natural capital gain.
It is unclear what ’environmental net gain’ means in the context of this policy and if this
requires more than ecological net gain measures. Paragraph 8 of the NPPF already defines
the environmental objectives of sustainable development as protecting and enhancing our
natural, built and historic environment; including making effective use of land, improving
biodiversity, using natural resources prudently, minimising waste and pollution, and
mitigating and adapting to climate change, including moving to a low carbon economy.
Environmental net gain could therefore encompass several features leading to confusion
in the interpretation and application of this policy and ultimately its soundness. This will
inevitably lead to issues for decision makers when trying to apply the policy to
developments.
If the Council’s ambition is to secure greater levels of green infrastructure or green
corridors to boost natural capital in the Borough, we would suggest this is best set out in
a separate strategic policy, which is informed by a Green Infrastructure Study to identify
areas of deficiency and opportunity. As this is a Borough-wide issue it requires a more
planned, joined-up approach underpinned by evidence to maximise opportunities to
improve the natural capital of the area, rather than relying on individual site appraisals
that risk a more piecemeal, uncoordinated approach.

Comment

Representation ID: 9960

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and L & Q Estates Ltd

Agent: Barton Willmore

we not the requirement for a 50% discount to be
applied to First Homes which is above the minimum 30% discount set out in national
policy. Whilst national policy does allow for the discount to be increased above 30%, we
do not believe that the Borough Wide Viability study demonstrates a clear position that
this approach to First Homes is viable. In fact, regarding affordable housing as a whole
there are potential concerns regarding several sites and the ability to deliver the 30% of
the whole mix.
In the absence of compelling evidence to justify 50% discount, and instead putting the
onus on developers through Policy DM2(S) regarding viability, is an unsound approach.
We instead suggest that the First Homes discount is reduced to 30% of open market value
which is consistent with National Policy.