Object

Representation ID: 10090

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Wilshamstead Parish Council is experienced in understanding the due process relating to public consultations and is therefore mindful of the importance of presenting clear and robust evidence at all stages, but in particular at this part of the consultation process, to ensure that Wilshamstead Parish Council makes clear its view as the first tier of local government. The Parish Council, has a further role as always, serving its electorate and ensuring they are supported throughout this phase, so considerable work has been done ensuring they are not only aware of the proposals and their direct impact on Wilstead, but also in engaging effectively in the consultation process.

The Parish Council also feels at this stage in light of the Local Plan shortly being taken forwards to government inspection, that with such a significant development earmarked and set out in the parish of Wilshamstead within this strategy document, that it is important to reiterate items that have previously been expressed.

Wilshamstead Parish Council, as usual, has been extremely pro-active in attending BBC led consultation events directed at local parishes, as well as the various public engagement activities within the consultation run by BBC. There has been a thoroughly review of the consultation documents, throughout the consultation period, as Parish Councillors have strived to understand more about the many different technical and complex items being considered. This is in addition to a huge number of important accompanying planning policy documents which will shape the future of Wilstead and communities across the Borough.

The Parish Council has facilitated a number of different ways to encourage Wilstead residents to engage with this consultation process, whether directly to BBC representatives or through feedback to Wilshamstead Parish Councillors. Throughout this consultation it has remained an absolute priority that all in Wilstead are aware of the enormity of the proposals, and that they can have their say and their voice heard. This has included using a village electronic circulation list, website publications and social media posts. Furthermore, signs were placed around the village to ensure those passing through (of which there are many every single day already) were aware of the potential impacts. These signs were sabotaged a few days later showing that personal interest is driving the presentation of the proposed sites in Wilstead. In addition there have been multiple communications made to the village population through the village magazine along with residents being welcomed to the July Parish Council meeting. The Parish Council also arranged a specific drop-in session on Sunday 10th July at Wilstead Village Hall to enable residents who had questions and/or required assistance with understanding to engage in responding to the consultation. The Parish Council knows the proposed allocations within this consultation are of interest to residents as over 130 attended the drop-in session.

It is also important to recognise that Parish Councillors are lay persons, volunteering their time, trying their best to review, consider and digest all the information relating to many different technical aspects of this Local Plan process. In addition, the volume of associated policy documents being consulted on, which again are also complex, however, are fundamentally crucial in the important role they play in the wider context of the development strategy.

As a result, it was important to Wilshamstead Parish Council that they focus on the impact the proposed allocations have on Wilstead - the area known best to Councillors.

RESPONSE SUMMARY

WPC objects to a number of different policies of the Plan document, these will be expanded upon later in this document under the requisite headings.

1. Misleading consultation representation
The Wilstead community feel it is important to recognise that the document has been misleading in how the specific site policies have been named which has resulted at best in misleading representation and is possibly legally unsound.

2. Capacity of Existing Resources
Any further development threatens the ability of existing resources to cope as these are often inadequate for existing residents and community governance issues not addressed in the Plan document. There is particular concern about build-up of traffic approaching the A421 from the A6.

3. The Need for Housing, Sustainable Development and the Environment
In this Section WPC expresses its support for questioning the overall number of new houses required.
We also repeat from our Neighbourhood Plan what sustainable development means for the village and cannot see how the draft Local Plan addresses these requirements in any way.

4. Potential adverse effect of major development in Wilshamstead Parish
There have previously been many concerns expressed about the Plan generating a large number of additional houses in Wilstead, which would result in a complete change of character of the village. Reasons against any substantial development are many and listed under this heading later in the document with focus on Policy HOU15 Land South of Wixams, Policy HOU16 Land at East Wixams and Policy HOU17 Land at College Farm, Shortstown. In addition Policy EMP 5 Pear Tree Farm Elstow together with the plans in Central Bedfordshire add to the proposal for surrounding Wilstead with development.

5. Settlement Hierarchy
The Parish Council recognises that some development may be unavoidable in Wilstead but would wish this to be restricted to that suited to a Rural Service Centre and to be consulted on any location. Assumptions made in the Bedford Borough Settlement Hierarchy continue to be based on inaccurate data both for Wilstead and for Wixams.

6. Coalescence
The increasing size of Wixams, Shortstown, Elstow and Cotton End threatens the separate identity of Wilstead which needs to be clearly maintained. During the life of the Local Plan 2040 this will result in the creation of an “urban sprawl” to the South of Bedford, without the necessary infrastructure or resources .

7. Neighbourhood Plan
The village has been preparing a Neighbourhood Plan since February 2017 and has had problems with support for the process during the Covid pandemic. Consequently it would not wish the Local Plan to pre-empt the important proposals already in draft form which include the allocation of Important Green Space designation to many of the sites identified under the “Call for Sites” process.

8. South of Bedford Policy Area
The Council has set out its response to this specific supplementary planning policy document.

9. Marston Vale Supplementary Planning Document
The Council has set out its response to the Developing in the Forest of Marston Vale Supplementary Planning Document which is a planning policy document being prepared by Central Bedfordshire Council and Bedford Borough Councils.

10. Conclusion
This sets out the Parish Council overall feedback to the consultation, reiterating reasons for objection.

Wilshamstead Parish Council do not feel assured that Bedford Borough are working with other Local Authorities to ensure a coordinated approach. The Parish Council have always been mindful that Central Bedfordshire has significant growth in many local areas. There is enormous growth only just a short distance along the A421 corridor with 5,000 houses currently at planning application stage for a strategically allocated site known as Marston Valley. But there is also more worrying continued large-scale development on the edge of the village (currently 1650 houses south of Wixams) which would further impact on the unique character of Wilshamstead village.

he Parish Council must reiterate how the proposed allocations for development on multiple sides of Wilstead are closing in, bringing increased worry over the rural village being totally engulfed.

There really needs to be a distinct and protected gap between Wilstead village and Wixams (to prevent “coalescence”) as well as between the very distinct communities of Wilstead, Elstow, Cotton End and now also Shortstown so that their historically separate identities are preserved. The potential size of any major development would threaten the very heritage of a village that is described in the Domesday Book.

The parish is rightly proud to be a close-knit community, able to support one another, however, growth in the wrong parts of a rural community will be damaging for not just the short term, but also for future generations to come.

Figure 12 Key Diagram, Page 83 in the consultation sets out an overview of proposed development for housing and employment sites. It shows a clear distribution of allocations heavily around the area south of the A421 now being defined as the South of Bedford Policy Area. However, the marking of the map again is misleading in that it represents the sites as if Wixams and Wilstead are both on the same side of the A6.







This is factually incorrect and is inaccurate.

Showing vague, poorly located blobs of roughly where allocations are is not helpful. Having spent more time looking at local policy maps relating to Wilstead parish it has shown the clear issue with the allocations HOU15, HOU16 and HOU17 in terms of coalescence.


The proposed development surrounding Wilstead is completely incompatible with the rural scene that has existed for centuries. The Parish Council has taken maps from the BBC “Changes to Policies” document dated April 2022 and merged Maps 8 and 11. It has also added in developments contained within the Local Plan for Central Bedfordshire.

The merger of all these proposals shows Wilstead surrounded by new housing with only small buffer areas shown. Wilshamstead Parish Council very strongly objects to this urbanisation of the area.

On the map on the following page the areas for development are shown with striped, pink vertical lines. (see attachment)

The Parish Council feel very strongly that there needs to be more done to protect the parishes, and Wilshamstead Parish in particular, to prevent the area becoming one large swathe of development.

Local Governance
The lack of forward planning on how this will be managed, will impact negatively on the established rural community of Wilstead. At no point is it clear in the consultation document on how the community governance arrangements will be managed for large housing development growth. Wilstead has first-hand experience of this, as Wixams grew, and then de-parished. The process brings many challenges, it is an uncertain time for residents, as well as being an exceptionally lengthy process with many complexities to navigate.

There needs to be clearer information on this set out within some part of the Local Plan around community governance, again with robust wording to ensure that communities can support their electorate and flourish.
SECTION 7 : NEIGHBOURHOOD PLAN
The proposed development of 2,100 houses within the parish boundary would directly contradict the first four objectives in the adopted Wilshamstead Neighbourhood Plan which are:

• To seek protection and enhancement of the countryside setting of the village, by ensuring separation from the urban edge whilst retaining access to the countryside.
• Identified green spaces, views and vistas and local wildlife habitats will be maintained and enhanced.
• To identify, protect and enhance village heritage assets and key public spaces, ensuring that any future development is sympathetic to the existing rural character of the village.
• To ensure any future housing responds to local needs, is of a high standard of design, and fits well into the context of the village in terms of type, mix, scale and character.

Thorough consultation was undertaken on the Neighbourhood Plan which demonstrates the value that local people place on the landscape and rural environment of the Parish. 95% of respondents agreed that the rural feel and access to the countryside are fundamental to the quality of life and community identity for Wilstead.

The Neighbourhood Plan for Wilstead was prepared to be in general conformity with the adopted Bedford Borough Local Plan 2030, having undergone extensive consultation with the community and stakeholders as well as BBC itself.

It includes policies to retain and protect the rural character of the Parish, to safeguard open spaces and prevent coalescence with Wixams, to ensure that new development is sensitively designed and that housing is suitable, to retain historic features and community facilities, to encourage local businesses and to tackle parking and traffic issues.

Five sites were identified in the Plan as “Strategic Gaps” to prevent coalescence with neighbouring communities. One of these Strategic Gaps is situated within the area identified under Policy HOU 16 and therefore this Policy is in direct contradiction to the Wilshamstead Neighbourhood Plan.

The Neighbourhood Plan is currently awaiting comments from the appointed examiner who has been made aware of this contradiction. It is expected that the Plan will go to referendum in the Autumn of 2022.

No housing allocations are being proposed in the Neighbourhood Plan, partly because the Local Plan 2030 did not require any allocations to be made, and partly because Wilstead has been subject to recent housing developments (over 100 houses or a more than 10% increase in numbers.). During consultation, residents reacted strongly against the notion of allocating any new developments of 10 houses or more, probably because of the existing level of new housing and a number of planning appeals that had been lodged in the Parish over recent years.

The Parish Council recognises that it is important to monitor the Neighbourhood Plan and check that progress is made towards meeting its objectives and policies and to respond to changes in the planning policy background. The Parish Council will consider
• if progress is being made to achieve the vision and the objectives of the Plan,
• if progress is being made towards the implementation of the policies in the Plan,
• if financial contributions available to the community arising from development are being targeted towards the identified plans and projects,
• if the Plan remains based on the most up to date information,
• if the Plan is being taken into account by Bedford Borough Council when determining planning applications.

The Parish Council will seek to work in partnership with Bedford Borough Council to liaise on future development of the Parish and will monitor progress on the Local Plan review and will consider whether to review the Neighbourhood Plan in line with the emerging Local Plan 2040.

If the emerging Local Plan 2040 is to require Wilstead Parish to accommodate further housing development in the period from 2030 to 2040, the Parish Council would prefer this requirement to be dealt with locally through a review of the Neighbourhood Plan which would allow much more local and focussed input from residents as to the location and type of development.