Object

Representation ID: 10039

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Southill Estate owns the land at Abbey Field West of Elstow, and supports the draft allocation for residential development and agrees with the policy requirements for the promoted development. The decision to allocate the land has been informed by the assessment of the site against selection criteria and constraints in the Housing and Employment Land Availability Assessment and Site Assessments, and in the assessment of the site against sustainability objectives in the Sustainability Appraisal Report. The site is consistent with the spatial strategy and distribution strategy contained in PSBLP. The site is also consistent with national policy contained in the NPPF, in terms of the preferred location for strategic development and accessibility by sustainable modes of transport.
A Heritage Impact Assessment has been prepared for the site to assess the impacts on heritage assets and set out mitigation and enhancement measures to address those impacts; the Assessment was submitted with the Southill Estate’s representations at Draft Local Plan stage in Summer 2021. An updated Bedford Innovation Campus Indicative Masterplan Document is submitted with these representations.

A more detailed commentary on these matters is provided below.

Policy HOU 5 identifies a number of key principles for the promoted development, which are included to ensure a high quality scheme and that the opportunities associated with the location of the site are delivered, and to ensure that significant constraints are addressed. For example, there are policy requirements relating to heritage assets, open space, green infrastructure, noise pollution, housing mix, access arrangements, pedestrian and cycle connections, education contributions, archaeology, flood risk, ecology, climate change, and water infrastructure. These policy requirements have been informed by the findings of the site assessment process.

The policy requirements in Policy HOU 5 are consistent with national policy contained in the NPPF. For example, there are sections of the NPPF that address housing (Section 5), communities (Section 8), sustainable transport (Section 9), design (Section 12), climate change and flooding (Section 14), natural environment (Section 15), and historic environment (Section 16).

The site was assessed in the Housing and Employment Land Availability Assessment and Site Assessments (Site Ref. 638). The site assessment identified potential constraints associated with nature conservation, heritage assets, and noise. The assessment identifies uncertain impacts for protected species, biodiversity net gain, agricultural land, and flood risk. The assessment includes detailed commentary on highway, transport and access matters. Policy HOU 5 include policy requirements for nature conservation (criteria vii), heritage (criteria i(a), and noise (criteria i(d). The policy requires an assessment of ecology, flood risk and drainage, and transport to support a planning application. In addition, there is a policy requirement for a masterplan and design code to be submitted with a planning application. Policy DM7 of PSBLP provides the general policy for biodiversity net gain that applies to all major developments, including the promoted development at HOU 5.

The site was assessed against sustainability objectives in the Sustainability Appraisal Report and Appendices – see SA Appendix pg. 174 to 175. The Southill Estate’s representations to the Sustainability Appraisal comment in more detail on the findings of the assessment, and request changes to the scores for some sustainability objectives. In summary, negative effects are identified for biodiversity and habitats, historic environment, previously developed land, and community services and facilities. Policy HOU 5 includes policy requirements to address impacts on biodiversity and the historic environment and ensure that mitigation measures are provided as part of the promoted development. The promoted development would provide pedestrian and cycle connections to enable residents to access the services and facilities available in the surrounding area. The identified development needs for PSBLP will require both previously developed land and greenfield sites. The medium and longer term impacts on biodiversity and habitats, historic environment, and services and facilities should be changed to neutral or positive because of the policy requirements in Policy HOU 5 for effective mitigation measures to be implemented as part of the promoted development.

A Heritage Impact Assessment has been prepared for the site to address impacts on heritage assets. In summary, it is concluded in the Assessment that the draft site allocation would change the wider rural setting of Elstow Conservation Area, the Parish Church of St Mary and St Helena, Church Tower, and the Elstow Manor House Scheduled Monument including Hillersden Mansion. This change would result in no more than a minor adverse impact to their wider rural setting and would have no impact on the immediate setting of the assets. The impact on the wider rural setting of these designated heritage assets would amount to less than substantial harm to the significance of these assets. The conclusion of the Assessment demonstrates that in terms of impacts on heritage assets it would be appropriate to allocate the site in PSBLP. In any event, there is a policy requirement to assess heritage impacts at planning application stage once more detailed information is provided on the design and layout of the promoted development.

An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development. This confirms that the site’s developers and landowners will continue to work proactively with Bedford Borough Council to bring forward the residential development of the site. This includes a commitment to meet the emerging policy requirements set out by policy HOU5.

It is noted that Policy HOU 5 does not specify the number of dwellings that could be accommodated within the draft allocation, which is an approach that is consistent with other strategic allocations. This site is included in the housing trajectory for 200 dwellings – see Appendix 1 in Stepped Trajectory Topic Paper April 2022. It is considered that the promoted development could accommodate more dwellings (approximately 400 dwellings) by increasing the density while still meeting all of the policy requirements. This is not a requested change to Policy HOU 5, but an adjustment is required to the housing trajectory for PSBLP.

In conclusion, the Southill Estate supports the draft allocation for residential development and agrees with the policy requirements for the promoted development. No changes are required to Policy HOU 5, but site capacity referred to in the housing trajectory should be increased to approximately 400 dwellings.