Comment

Representation ID: 10091

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

The Parish Council immediately on publication of the formal consultation and related publicity material raised concern directly with Planning Policy Officers at the local authority on the misleading naming of proposed local plan locations as a “Wixams Extension”. Officers outlined that sites were being classified by their geographical locations, this however, has not been a helpful representation for the Wilstead community and it was noted at our open day repeatedly that the Local Plan was misleading and confusing as many residents believed it was a further extension to Wixams on the other side of the A6. Both HOU15 and HOU16 should have been known as Land West of Wilstead (HOU15) or Land North of Wilstead (HOU16), just like policy HOU5 Abbey Field, West of Elstow which makes a clear reference to the parish it is in. In response to a question during an on-line discussion about this misrepresentation the Planning Department replied that they were sure Wilstead Parish Council would make it clear to Wilstead residents that the proposals were within the Wilshamstead Parish. This is unacceptable. The Parish of Wilshamstead is severely affected by the proposals in the Plan in that it appears to propose reducing the size of the Parish by approximately one fifth, significantly impacting upon walking routes, biodiversity and dramatically increasing through traffic whilst also transitioning this land and the applicable services within it to Wixams. Nowhere in the document is this made clear.
Wilstead is mentioned only 7 times in the document and only in terms which support the preservation of the village in its current form.

It could be predicted that in shifting one fifth of the current Parish of Wilshamstead to Wixams the Wilstead community would not only suffer the effects described at length within this document but would also not benefit from any Community Infrastructure Levy received from developers that could act as some mitigation for the loss and overburdening of current resources.

The inaccurate naming of the two proposed allocations within the draft Local Plan and consultation documents is a significant issue in that it is misleading the public and inaccurate in its nature, casting doubt on the accuracy of the Plan as a whole and something that may become subject to legal challenge at a later stage.

At most, members of the public will glance or briefly scan such a local authority document at best, whether that is the literature produced in text, or visual format. For many, on doing that, it appeared that the Local Plan 2040 document aligned with the adopted and well supported Wilshamstead Neighbourhood Plan allocation of no additional housing.

However, both HOU15 and HOU16 clearly sit entirely within the parish boundary of Wilshamstead, as illustrated on the map below. (see attachment)

This misrepresentation of information will have resulted in many not understanding the proposals. Often, when individuals see no direct impact, they do not go into a more in-depth review of the consultation and therefore are unlikely to give feedback or engage in the consultation process. This is relevant to those that live in Wilstead, as well as those who live nearby in Wixams who have also been misled. The knock-on impact of this inaccurate site naming will also spread beyond the nearest settlements, with many across the borough believing that the proposed developments are in Wixams, which is well known in terms of having been a new town, created to serve a growing new community. Totally distinct from ‘Wilstead’ which is recognised across the borough as a rural village.

Removing Wilstead from the policy site names, feels like an attempt from the local authority to disguise significant development for the village community and to directly mislead the public in order to establish new development without significant objection.

SECTION 2 : CAPACITY OF EXISTING RESOURCES

Overview
The village has already had to accept development of 105 houses as its contribution to the Local Plan 2030. This is an increase of over 10% which has already threatened to overwhelm local facilities, such as the local village school and the secondary school at neighbouring Wixams, both of which are at full capacity.

Local Plan 2040 Specific
The village is now faced with Policy HOU15 and HOU16 which bring an increase of 2,100 houses over the lifetime of this new Local Plan. It is unclear in the consultation on how Wilstead is expected to cope with such an influx of housing development as it certainly does not have the infrastructure to manage this, and the proposed developments do not bring such facilities to support the drastic growth without substantial funding which, in the past, has not been forthcoming.

Furthermore, the road network locally is already an issue with Wilstead being the connecting road from Wixams (as it is today) through to the A600. Notable speeding issues have not yet been sufficiently addressed by BBC and we are now faced with a potential increase in not only traffic once the site is built, but also a huge amount of polluting vehicles bringing goods and materials, workmen and equipment during build.

It is not clear from this document how such a rural village would cope with a population increase of circa 5,000. It might be argued that such densely populated areas may look to Wixams Town Centre, however, that still remains some time off in the future. Initially new residents will look to Wilstead or Village 1 at Wixams, both of which have very limited facilities (see the argument below on inaccurate Settlement Hierarchy evaluation).

Whilst the consultation document places generic aspirations for the development growth areas it is important to remember there are specific local factors that need to be taken into account. Development cannot be in the direct path of water draining from the Southern escarpment (Greensand Ridge) or in the lower levels north of the village centre, which are shown on Water Authority documentation as at risk of flooding from drainage ditches. Each housing policy area has an overarching ‘mitigation required for all sources of flood risk where necessary’ but they are site specific. Cumulative impact does not appear to be referenced which has a knock-on effect to all residents who can then find water draining problems occurring. Since the development at land off Whitworth Way known as Wooding Way the knock-on effect has been noticeable further afield in the village.

Public transport or cycling are not realistic alternatives for people in the area to get to work or to go shopping. The bus service in Wilstead is very limited. There is no East to West or West to East service despite the village stretching nearly 2 miles in that direction. In addition, bus stops for the service to Bedford are located more than 800m from the majority of residents. The existing bus service along Luton and Bedford Roads in Wilstead is unreliable and infrequent leaving gaps of one hour at many peak times.

For cycling or walking it would be necessary to cross the A6 from HOU 17 to reach existing facilities in Wixams which would be extremely dangerous and the draft Plan shows no suggestion as to how this danger may be mitigated.

A full study was commissioned by the Borough Council for the current Local Plan 2030 on the effect of proposed additional traffic on the A6 approaching from the North into Bedford. This was the main reason that large developments north of the town have been ruled out. The research carried out by AECOM on the effect of the increase in traffic approaching from the South if these developments were to go ahead is inadequate and does not show the effect of so much more traffic being generated by the proposed developments in Wilstead, by the cut-through traffic from, and to, the A600 and the large developments proposed close to the A6 by Central Bedfordshire Borough Council. The build-up of traffic approaching the A421 or the new Wixams station would be extreme and no proposals are evident of mitigating road changes. There is also no evidence of any air quality targets or measures to mitigate the impacts of climate change beyond very high level statements and an ever increasing amount of tailbacks on the northbound A6 as it meets the A421.

The biggest cumulative impact that will be seen within the parish will naturally be around highways and further increases in traffic on the already overwhelmed existing busy rural roads which have become very congested at school opening and closing times throughout the rush hour period as the village is used as a ‘rat run’. The Parish Council have extensive data from local surveys, Police and local authority survey with the problems experienced, particularly along Cotton End Road. Traffic originates from outside the village and is an indication of how development outside of the Parish Council’s area has in turn adversely affected the resources within the village. There is still no local Health facility in Wixams or Wilstead and the weekly access to doctor’s services in Wilstead has been discontinued. In addition the number of new houses proposed in the Central Bedfordshire Local Plan will mean that doctors used by Wilstead residents in Ampthill will become even less available. There is no indication in the draft Plan as to how the additional 28 GPs identified in the AECOM Infrastructure document could be recruited to serve the number of new residents proposed in the South of Bedford Policy area.
Further concerns exist around schooling. A 9-form entry (FE) secondary school and two 2-FE Primary Schools within HOU 16 is an ambitious target that would require massive funding and resources that would not be forthcoming in the short-term, thus putting even more pressure on existing schools in the area which are already at capacity.
Infrastructure concerns are further addressed in Section 8 of this response addressing the South of Bedford Policy contained within the proposed Plan.

SECTION 3: THE NEED FOR HOUSING, SUSTAINABLE DEVELOPMENT AND THE ENVIRONMENT

Wilshamstead Parish Council appreciate the work behind the document from the Campaign for Rural England dated July 2022 in which they question the need to find 27,100 additional houses between now and 2040. WPC accept that BBC has made the point to the Government that they “are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.” But feel that the Borough should not just lie down and accept that no flexibility in the numbers can be shown.

The National Planning Policy Framework (NPPF) states that pursuing sustainable development includes making it easier to create jobs in villages, promoting gains in biodiversity, achieving better quality design, improving people’s quality of life and providing a wider choice of high-quality homes. It is unclear how these can be achieved based upon the broad terms included in the draft Plan.

Within the Wilshamstead Neighbourhood Plan we list what sustainable development should mean for the village. It should be:
• At an appropriate scale and in locations where it would support the community,
• Of a high standard of design, reflecting the rural and historic character of the surroundings,
• Contributing towards community infrastructure,
• Providing superfast broadband (fibre-optic) connections,
• Ensuring that there is no increase in the risk of flooding,
• Meeting contemporary construction, energy efficiency and water management standards,
• Located and designed to enable safe walking and cycling to local services and facilities, preferably within a 400m radius of those locations.

WPC cannot find the detail within the draft Local Plan of how any of these can be achieved.

In addition the Neighbourhood Plan states that the following adverse impacts must be avoided:
• Reduction in the physical separation between the village and Wixams,
• Avoidable intrusion into open countryside,
• The loss of or damage to wildlife habitats and hedgerows and trees,
• The loss or inappropriate diversion of public rights of way,
• A loss of amenity for existing residential properties and reduced efficiency for nearby businesses,
• Overloading existing utilities and services (water, drainage, sewerage and waste).

None of these concerns appear to have been addressed by the draft Local Plan 2040 and a number are directly contradicted by proposals in that Plan.

WPC support the CPRE Bedfordshire proposal that all open green space within new housing development should be handed over to Town & Parish Council's for long term maintenance and not held onto by developers who charge residents much higher maintenance costs. We receive regular complaints about this in existing developments in the village. We agree with CPRE and can ourselves find no reference in the Draft Plan to any steps taken to address this

Paragraph 6.62 of the Draft Plan refers to “environmental net gain” but nowhere can we find an explanation of what action is to be taken to achieve this.

Other aspects of sustainability are that you should not use sites that are valuable from an agricultural/environmental/recreational perspective for development. All of the land proposed for development is on key agricultural land and HOU 16 borders an important footpath used daily for recreational activity and a Community Woodland planted recently for that very purpose.

SECTION 4: POTENTIAL ADVERSE EFFECT OF MAJOR DEVELOPMENT IN WILSHAMSTEAD PARISH

Village Overview
There are only approximately 900 houses in the village (plus 196 park homes), therefore any substantial development would completely alter the character of the community and overwhelm its already overstretched facilities. The addition of 2100 houses would mean the village housing number would become three times the current size until such time as the land is annexed off into Wixams at which point the village would become dwarfed by its neighbour and would further lose its small, rural feel.

Wilstead is a rural community, which it is vitally important to retain. Securing its rural feel is essential and emphasised repeatedly in responses from villagers to the consultations on the Neighbourhood Plan. This should be achieved by maintaining a large number of green spaces, strategic gaps between settlements and important views into the surrounding open countryside.

The village has consisted for centuries of separate “Ends” (e.g. Duck End, Church End, Littleworth). These should remain separate to preserve that rural Bedfordshire heritage, not only in the timeline of this Plan but for future generations to come. The map on page 67 of the Plan shows arrows to denote “Local Gaps”, This completely ignores the fact that the Duck End community is next to the proposed area for development under HOU 16.

The existing, very stretched, “Ribbon Development” of Wilstead would not tolerate further development on its edges (or moreover on land completely disjointed from the traditional development style seen to date) without these developing into separate communities in themselves and necessitating additional car journeys and the further and unnecessary use of natural resources which is in itself unsustainable and unnecessary. Wilstead is a settled community and the Parish Council do not wish development to introduce separation, meaning therefore, that any development to the village would have to be more central and consistent with the existing size of the village. It should be noted that further development in the village has been managed successfully to that end to date whilst simultaneously maintaining a rural and peaceful area.

Wilstead is incredibly lucky to have a wonderful range of footpaths and bridleways and quiet country roads within the parish; perhaps most notably the historically important John Bunyan trail. They are very popular with cyclists, walkers, bird watchers and horse riders. A wide range of people not only from Wilstead but also surrounding villages, including Wixams, use them to enjoy the tranquillity, the wildlife, the views or just to get exercise and for mental well-being. There are 11 miles of footpaths and bridleways within the Parish Footpaths, the use and enjoyment of rights of way would be detrimentally impacted with the proposed allocations, especially as the proposed HOU 16 would adjoin a much-used footpath (part of which is on the John Bunyan trail) and HOU 15 would be dissected by an existing footpath.

Proposed Allocations Objections
Substantial development has been included in the Local Plan document with Policy HOU15 and Policy HOU16. The Parish Council is also mindful of the sizeable allocation for Policy HOU17 Land at College Farm, Shortstown which will be addressed as well in this response.

The Borough Council indicates that as a result of previous consultation it is going ahead with a recommendation for “Option 2b” of its previous proposals. This Option refers to an additional 5,500 houses in Kempston Hardwick, Stewartby and Wixams and 1,500 spread between Wootton, Kempston, Shortstown , Cotton End and Wilstead. Policies HOU 15, HOU 16 and HOU 17 show 3,100 houses for Wilstead and Shortstown alone. Option 2b is therefore not what is being proposed and the detail within the proposed Local Plan has therefore not been consulted upon.

All three of the allocations above if taken forwards as strategic growth options by the local authority, would most likely consist of estate-type development which would be out of character with the rural, multi-age and mixed style of the current range of dwellings.

In addition for sites HOU15 and HOU16 if they were to be developed it would be mean for both major developments in Wilstead it would necessitate people travelling by car into other communities, as these resources do not exist locally in the parish. Examples include:
 Schooling (insufficient places available locally)
 Shopping (local store cannot supply the range of goods required)
 Health facilities (none locally)
 Onward bus or train travel (very limited services)

Policy HOU 15 Land South of Wixams (i.e. West Wilstead)
In addition to the Parish Council objecting to this proposed allocation for the planning policy reasons set out above, the Parish Council wish to highlight in particular for this site, the detrimental impact in terms of coalescence (see Section 5 below). The location of this site is key to retaining segregation of the two distinctively different communities. Development in this area places a huge risk to Wilstead and the Longmeadow Drive area of the parish becoming subsumed as part of Wixams.

The Parish Council also feel it is important to highlight specific areas of the associated planning policy which if the site remains allocated, must be amended prior to Secretary of State scrutiny.

Paragraph 4.86 makes no reference of the site within Wilstead parish or its proximity to Wilstead, these omissions are not acceptable.

The policy wording makes a brief reference to a long-term buffer between Wixams and Wilstead, however, this is not reflected in Figure 8 of the consultation document within the site boundary. This is concerning as in many other site maps illustrating proposed allocations there has been distinct reference already included of important areas identified as key open spaces even at this strategic level. Such safeguarding of areas can be included at this stage of the Local Plan. Again this omission is concerning for the Parish Council.

In light of the landowner/site agent representations within the ‘Call for Sites’ process it is clear the aspirations for this site are considerably more than the 300 proposed allocation. Given recent experiences of sites that have come forward, the Parish Council are mindful it is often the wish of the developer when bringing a site forwards to place as many houses on as possible to maximise revenue output. It is therefore reasonable that if this site remains included that it must have written into the strategic policy robustly a definite number of houses, alongside the key earmarked open space areas to act as a strategic buffer. Without this change and inclusion within the policy there is no safeguard or protection for the site to not be fully developed and given the site has capacity to hold well over 1,000 houses this is really a concern for the Parish Council.

Policy HOU15 wording is not clear enough on a number of important factors that must be stated within the overarching policy if this site goes forward. There are too many ‘loose’ words which during the development of Wixams resulted in so many expectations not being met. Together with the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and resulted in many ultimately never being delivered or being many years late.

The Parish Council feel that there needs to be more included with the Transport Assessment, with higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport, such as a clear and specified Local Transport Decarbonisation Plan, following the Government’s commitment to Net Zero, the national EV Infrastructure Strategy and supplementary Transitioning to zero emission cars and vans: 2035 Delivery Plan which will incorporate not only the traffic related to the construction activity (which typically sees large diesel-powered HGVs operating) but also the longer-term operation of fleets and commercial vehicles in these areas. This plan must include the provision of sufficient e.g., charging hubs, destination charging and on-street charging to supplement the now mandatory home charging sockets. It should also be a requirement of the development to provide sufficient non-motorised options for sustainable transport, such as cycling routes and walkways away from the roadside (for safety and emissions reasons).

In item iv. it talks of ‘provision of a mobility hub’, this needs to be defined in more detail as otherwise it becomes just a piece of land that is allocated but has nothing of any useful benefit on it. Infrastructure is critical to ensuring a community can grow. Further to this, the provision of energy for the site should be mandated within the policy document to come from localised generation.

Again there needs to be more robust wording in items vi. viii. and ix. With some more substantial statements referenced.

Item x. makes reference to preserving and enhancing heritage assets and their setting, ‘including assets located in Duck End and Wilstead.’ Whilst it is important that Duck End is recognised as an important area which includes 3 listed buildings, there are plenty more assets in close proximity to this site allocation that should be included and specifically named in the policy wording, including All Saints Church and 19 other Listed Buildings within the Village.