Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10092

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Likewise for this proposed planning policy, in addition to the Parish Council objecting to the proposed allocations for the overriding planning policy reasons set out above, the Parish Council wish to highlight in particular for this site, concerns about the development area as illustrated on Figure 8.

The location of this site is a real concern as it sets total precedent for high density estate development east of the A6 within Wilstead parish. For many years land that side of the A6 and the village road into Wilstead has been put forward for planning, and refused, rightly so. Such an allocation with Policy HOU16 would have a significant knock-on effect.

The proposed Settlement Policy Area for HOU16 also extends a long way eastwards, again a concern given the large land masses along Cotton End Road in Wilstead which have received planning applications for housing development in the past. Whilst they have been refused previously, it does bring concern that this allocation could set a precedent.

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.

Overall, the two largest areas marked on Figure 8 identified for potential housing development are situated a considerable distance away from the A6. Figure 8 clearly shows that development abuts the A6 fully on the western side. It seems more logical and natural, that the third potential development area currently located on the south west corner of the proposed allocated site, is moved upwards to be in line with the larger two masses as depicted by the red arrow below. Alternatively if this revised location is not acceptable, being then situated in a Flood Zone it should be removed altogether.

Equally for this Policy HOU16 site the Council feel in light of the landowner/site agent representations within the ‘Call for Sites’ process it is clear the site can hold significantly more than the 1800 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 enough for a new town this is really a concern for the Parish Council.

Again the Parish Council feel that Policy HOU16 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 again too many ‘loose’ words which during the development of Wixams resulted in so many expectations not being met, alongside the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and many ultimately never were delivered.

Paragraph 4.87 makes no reference of the site within Wilstead parish or its proximity to Wilstead, these omissions are not acceptable.

The Metrological Research Unit at Cardington is referenced, having tried to better understand the impact this has on the site, in terms of planning policy, this is not clear. It would be reasonable for such an item considered to be so significantly important to be mentioned in the planning policy that somewhere there is clarity on what such a reference actually means along with the types of mitigation that will need to be factored in. The reference is made in both paragraph 4.87 as well as Policy number i. so it must be an important item.

Item iii. references transport improvements are required, in fact the development is dependent upon it. Again the policy wording is insufficient and unclear, this needs to be defined.

The Parish Council feel that there needs to be more included with the Transport Assessment point number iv. it seems illogical that a site for 1800 houses has less requirements stipulated in the associated policy than Policy HOU15 which is to have 300 houses. Surely as a bare minimum the four bullet points contained within HOU15 should be referenced in HOU16. Along with, as mentioned previously, the local authority needing to have higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport. As highlighted in the above section, all such development activity should be mandated to have localised, on-site generation to mitigate the impact of the site by ensuring renewable energy is used in the local transport and heating solutions from the point of breaking ground and beyond.
In item vi. it talks of ‘provision of a mobility hub’, this needs to be defined in more detail as otherwise 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.

Again there needs to be more robust wording in items vii. viii. ix and x and education infrastructure. Previous issues as outlined already with empty spaces for facilities to be built when infrastructure needs to be available to support the community before it grows.

Item xii. makes reference to preserving and enhancing heritage assets and their setting, ‘including assets located in Duck End. In Policy HOU15 this statement referenced ‘and Wilstead’, it appears inconsistent that there has been no reference of Wilstead which contains 23 listed buildings that will need protecting.

It is also noted that there is no policy wording as in Policy HOU15 stating ‘submission of a wildlife and habitat survey with appropriate mitigation and enhancements.’ The Parish Council request this must be included if the site is taken forwards, it is an extraordinary omission given Policy HOU16 is adjacent to a community woodland area in Duck End which also has a designated area for Great Crested Newts - very much a protected species.

The Parish Council would like to reiterate the concern with this allocation with regard to its close proximity to the Duck End part of the village. The boundary abuts this unique setting of dwellings which are all of historic value. The houses along the western side of Bedford Road will have their outlook changed forever, so this reiterates the importance to protect those views as much as possible by moving or removing the proposed development area identified on the map above by a red arrow.

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