Bedford Borough Local Plan 2040 Plan for Submission

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.

Comment

Representation ID: 10314

Received: 29/07/2022

Respondent: Castlecap Investments Ltd

Agent: Lichfields

Policy DM1(S) sets out the Council’s affordable housing requirements. This policy should also confirm
the type of affordable housing to be provided in BTR schemes, i.e. discounted market rent units. The
policy is not sound without specifying the affordable housing requirement for this tenure, especially
given BTR is referenced elsewhere in the draft Plan.

Comment

Representation ID: 10315

Received: 29/07/2022

Respondent: Castlecap Investments Ltd

Agent: Lichfields

We also consider that to be sound, the Local Plan should include updated parking standards. BBC’s parking standards are set out in the Parking Standards for Sustainable Communities SPD 2014 – given the time that has elapsed since this document was published the Council should review the standards.
NPPF paragraph 107 confirms that parking standards should take into account the accessibility of the development, the type, mix and use of development, and the availability of and opportunities for public transport. Therefore, to be in accordance with national policy and therefore sound, BBC’s parking standards should provide more flexibility for town centre sites, which have good public transport accessibility, to provide less car parking than suburban/rural sites. It should also reflect that certain residential products will typically require less/no car parking, compared to private sale units.