Comment

Representation ID: 10011

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

8.1 Wates supports this draft policy in principle and agrees that Land South of Wixams represents a sustainable and suitable site for growth. A residential development at this location would relate logically to the current and permitted extent of the Wixams New Town, with the site adjoining ‘Village 2’ to the north west.
8.2 In addition to adjoining the settlement, the vast majority of the site is bound by the A6 road. Whilst a small parcel within the proposed allocation lies to the east of the A6, this is only included in order to allow for the formation of a new vehicular access, via a roundabout junction. The development of the land would therefore present an opportunity to ‘round off’ the south eastern extent of Wixams, without significant encroachment into the open countryside.
8.3 To the south, the proposed allocation extends along the route to the A6, as far Wilstead. This part of the site is not promoted for residential development. Rather, it presents an opportunity to provide a new area of (publicly accessible) woodland, contributing to the broader objectives of the Forest of Marston Vale strategy and exceeding the draft Policy HOU12 objective of achieving 30% woodland coverage within the Forest of Marston Vale Area.
8.4 As we detailed below, the site is free from any significant constraints that would prevent a sustainable development being achieved. It is deliverable and capable of making an early contribution to the supply of land for housing.
8.5 However, Wates considers that the precise wording of the proposed policy requires modification in potentially significant ways, in order to improve the potential for early delivery, and hence the effectiveness of the policy overall. As such, Wates objects to the policy as presently worded.
Consideration of Constraints and Opportunities
8.6 Land South of Wixams currently comprises approximately 50 hectares of predominantly arable land, which is intensively farmed. Consequently, an Extended Phase 1 Habitat Survey (included in the Ecological Appraisal at Appendix 6) confirms that the majority of the site is of low ecological value. Habitats of interest are largely limited to boundary hedgerows and trees, and ponds. The baseline ecological value of the land is such that it will be possible to achieve the 10% biodiversity net gain sought by draft Policy DM7.
8.7 In terms of arboriculture, a Tree Survey has been undertaken. This confirms that no Tree Preservation Orders (TPOs) apply to the site, nor are there any areas of Ancient Woodland within or adjoining the land. A small area of mature woodland is situated in the far south of the proposed allocation. However, this is located a considerable distance from the envisaged developable area and would form part of the proposed woodland.
8.8 The Tree Survey has been used to inform the emerging masterplan, which will retain existing trees and hedgerows wherever possible. Development at this site would therefore be comply with adopted Local Plan 2030 Policy 39 (‘Retention of Trees’) which is proposed to be ‘saved’. The development also has the potential to facilitate the creation of a large new woodland, greatly increasing canopy coverage. In this way, the proposals will contribute to the requirements of draft Polices HOU12 and HOU15, as well as adopted Policy 36 ‘Forest of Marston Vale’ (as is proposed to be saved).
8.9 Consistent with the requirements of draft Policy HOU15, the accompanying Historic Desk Based Assessments and Heritage Technical Note (Appendix 5) indicates that conventional assessments of below ground archaeology11 will be required to support a future planning application at the site. The draft policy also makes reference to above ground heritage assets at Duck End and Wilstead, indicating that these will need to be preserved and (where possible) enhanced.
8.10 The appended details confirm that all of the heritage assets in Duck End and Wilstead are dislocated from the site by the A6 Road and other intervening built form. On this basis, the site makes no apparent contribution to the setting of any of the assets identified, with this inherently reducing the potential for detrimental impacts to occur. The site could therefore be developed in a manner consistent with adopted Local Plan Policy 41 ‘Historic Environment and Heritage Assets’ (as proposed to be saved) and NPPF Section 16.
8.11 Regarding landscape, the site is not within any designations for ‘valued landscapes’, such as AONBs or National Parks. It does currently fall within a ‘Local Gap’, as identified at Policy AD42 of the ‘Allocations and Designations Local Plan Policies’ (2013). However, a landscape-led approach, the introduction of appropriate buffers and the proposed new woodland, means that the effectiveness of the retained gap will be maintained (in a manner consistent with draft Policy HOU15).
8.12 It is also the case that the northern extent of the site, where the developable area is envisaged, is less sensitive in landscape terms. This is because the localised character of this area is influenced by the A6 and the urbanised context of the Wixams New Town. These characteristics are consistent with the classification of the ‘Clay Vales – North Marston Clay Vale’, as identified in the conjoined Bedford Borough and Central Bedfordshire Landscape Character Assessment (January 2015). The site’s development is therefore expected to accord with adopted Policy 37 (‘Landscape Character’), which is proposed to be saved.
8.13 Noting the presence of the A6 road (and consistent with the requirements of draft Policy HOU15) an Acoustics Assessment (Appendix 9) has been undertaken at the site. This confirms that a future residential development can meet required standards and secure an acceptable acoustic environment, subject to the inclusion of conventional mitigation measures. The Assessment further confirms that it may be appropriate to include a buffer towards the road. However, the width of the recommended buffer (as identified through this technicalassessment) is more limited than that presented on the Strategic Concept Plan at Figure 5 of the Draft Local Plan.
8.14 The accompanying Preliminary Drainage Strategy (Appendix 10) confirms that the site is generally situated within ‘Flood Zone 1’, which denotes a low probability of flooding from fluvial sources. A small area along the northern boundary of the site is identified as ‘Flood Zone 2’, with this being associated with an existing watercourse. No development is proposed within the area.
8.15 A surface water drainage strategy will support a future planning application at the site. In-situ ground investigation and infiltration testing surveys have been undertaken to inform this. These suggest that surface water run-off will need to be addressed though SuDS, in the form of conveyancing swales and detention basins. The SuDS infrastructure will be integrated into a holistic strategy for green and blue infrastructure, which will contribute to landscape enhancements and net gains in biodiversity.
The Proposed Development
8.16 A Vision Document accompanies these representations, which provides a comprehensive account of the development proposals envisaged at the site.
8.17 However, in summary, the guiding principle for the site’s development will be the pursuit of a landscape-led approach. This will be achieved primarily through the distribution of land uses, with development being limited to those parts of the site which best relate to the existing extent of Wixams and which are less sensitive. Conversely, a new area of publicly accessible woodland is proposed in the more sensitive land to the south / south east.
8.18 A buffer is envisaged along the western part of the site, towards the A6. This will assist in preserving the amenity of future residents, whilst also providing separation from the existing dwellings at Duck End. A further green buffer is envisaged within the northern extent of the site, where the allocation adjoins the existing / permitted extent of Wixams. Following from this, development at the site will aim to create a distinct ‘village’, thereby pursing an approach that is consistent with the existing pattern of development at the settlement.
8.19 Extensive areas of Green Infrastructure will be provided in the form of public open space, not least a large new area of woodland and country park, that will support the Marston Vale Community Forest project and which will benefit residents of both Wixams and Wilstead. Significant areas for biodiversity enhancement will be provided across the site, ensuring that net gains above 10% will be secured12. New SuDS features will include ponds and swales, which will further contribute to landscape and biodiversity objectives.
8.20 In terms of vehicular access, the site is to be served by a new three arm roundabout taken from the A6 to the east. For non-motorised users, access will be delivered to the PROW network and to Bedford Road where there are opportunities to deliver either a dedicated shared footway and cycleway connection and / or a bus connection onto Bedford Road. The key principle in this regard, is to promote pedestrian / cycle connectivity into Wixams and Wixams Train Station, when this is delivered.
8.21 It is considered around 430 dwellings could be achieved across a net developable area of 11.5 ha, representing an average net density of 38 dph (net). Development densities will in practice vary across the site, with the development being structured around a number of distinct character areas. In this way, the proposals strike a balance between an efficient use of land, whilst also responding appropriately to the site’s context.
8.22 The new homes will include policy-compliant levels of affordable housing, with the mix and composition of the new dwellings ranging from flats to townhouses and detached / semi-detached homes. All of the new homes built at the site will conform to national and local planning standards and building regulation requirements relating to energy efficiency and ‘zero carbon ready’ development.
Development Density
8.23 An important consideration for any development is that of density. In this respect, it appears that BBC has underestimated achievable net densities at the site. Specifically, a density of around 30 net dwellings per hectare (dph) appears to have been assumed by BBC, in the reports associated with the consultation13.
8.24 The level of density appears combatively low when compared to the Wixams Park development, and Wixams Villages 1 and 2. This is illustrated by the analysis of built / approved density strategies within the accompanying Vision Document (at pages 36 to 37). The analysis illustrates the prevalence of densities within the ranges of up-to 35 dph, 35 to 40 dph and 40 to 50 dph, with densities even exceeding 50 dph in particular locations.
8.25 Localised densities therefore vary greatly across the existing settlement, as they will indeed vary across Land South of Wixams when it is developed in future, as an extension to the New Town. Indeed, Wates proposes a range of house types and sizes, in accordance with draft Policy DM3. Achieving a well-conceived design will result in natural variation, as townhouses and/or apartments might front main streets, whilst lower density detached / semi-detached properties would line secondary streets.
8.26 Nonetheless, average net developable densities should not be lower than 35 dph at the site. Wates maintain that this is appropriate and reasonable, as new development with this allocation will form part of Wixams, which (as a contemporary New Town) is already characterised by higher densities than might be associated with a historic or post-war settlement. Indeed, there do not appear to be any character-related constraints that would point to a need to limit expected densities to just 30 dph (net).
8.27 Wates consider that an average density of 38 dph could be comfortably achieved, which suggests that capacity of the site is around 430 homes. This is based on our assessment of the available developable area (11.15 ha), taking account of the proposed strategy for SuDs and infrastructure provision, and applying appropriate buffers for to account for landscape and acoustic constraints. The approach to scheme design and developable area is detailed in the appended Illustrative Masterplan, Vision Document and supporting technical reports.
8.28 This volume of development appears to be achievable and would be appropriate in the context of the existing pattern of settlement at Wixams. Increased densities are also consistent with the pursuit of low / zero carbon development, as set out in draft Policies DS1, DS2 and HOU12.

9.2 Within the context of the proposed spatial strategy, it is entirely consistent for further development to take place at Wixams. The settlement is already identified as a key service centre, that benefits from an expanding range of modern local services. Indeed, Wixams will soon benefit from additional strategic transport infrastructure in the form of the new Railway Station. Having been established as a new town, the settlement has continued to develop and deliver significant volumes of new housing.
9.3 The development proposed through Policy HOU15 ‘Land South of Wixams’ therefore represents a logical approach to meeting housing needs, through a modest extension to the settlement. The developable area within the north of the site is well contained by the A6 road and the current extent of Wixams, whilst the southern part of the proposed allocation is capable of accommodating large new areas of public open space and woodland.
9.4 Contributing to the Forest of Marston Vale project, the new accessible area of woodland / country park would provide tangible benefits for residents of both Wixams and Wilstead, particularly in terms of health and outdoor recreation. The introduction of this new woodland will also dramatically increase canopy coverage in the local area, and will create widespread opportunities for biodiversity gain and (over-time) carbon sequestration. In this way, the proposed allocation addresses sustainable development, and particularly the environmental and social aspects of the NPPF paragraph 8 definition.
9.5 Land South of Wixams is actively promoted by Wates and consideration has been given to key design principles, including a landscape-led approach and promoting connectivity. A Vision Document accompanies these representations, which sets out the proposed strategy in more detail. This is supported by a range of technical surveys and reports, which confirm that the site is free from any technical constraints that would impede its delivery. The development will therefore make a timely contribution to the supply of market and affordable housing.
9.6 Whilst Wates strongly supports the principle of both Policies HOU12 and HOU15, Wates raises objections to the current wording on these policies. Subject to the modifications outlined in these representations, we believe that these policies can be made sound. Wates also objects to the wording of Policy DS3, as (on reviewing aspects of BBC’s identified housing supply), there would appear to be an opportunity for greater delivery, within the early to middle part of the Plan-period. With modification, it is considered that this draft policy can be made sound.