Object
Plan for submission evidence base
Representation ID: 10161
Received: 29/07/2022
Respondent: J C Gill Developments Ltd
Agent: Optimis Consulting
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Introduction
On behalf of J.C Gill Development Ltd, I am pleased to formally submit representations to the Bedford Borough Local Plan 2040 Regulation 19 (Pre-submission) consultation together with the Response Form accompanying this letter.
We object to the spatial strategy set out in the draft Local Plan as matter of principle because it does not propose to allocate the most suitable site’s in the most suitable locations. The approach taken by the Council is flawed, not only because it fails to recognise the more sustainable locations for growth, but also because it overly relies upon the delivery of site’s that are in less sustainable locations and rely on the delivery of substantial infrastructure projects that are uncertain and likely to cause delay. The full details of the objections are presented in this representation.
In order to assist the Council in preparing a sound and credible plan we advocate those additional site’s are allocated in locations that are sustainable, meet the vision and objectives set out in the plan and present a significantly more deliverable and robust housing allocation.
The Proposed Allocation
Site Details
The site is located between no.34 and no.36 High Street, Riseley. It has not previously been promoted for inclusion in the Local Plan, however, following assessment of the draft document it is considered it could prove valuable in quickly delivering short term housing need. The site, approximately 0.65ha, is located in the southern area of Riseley, a Group 3 village. Access is available directly from High Street on the northern corner of the site. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1.
[See attachment for Figure.]
The site comprises of an open field, lined by trees and hedgerows on three boundaries and post and rail fencing on the south eastern boundary. It adjoins existing residential development on its north eastern and south western edges and a Police Station and further residential development to the north west beyond High Street. Land to the south east, beyond post and rail fencing, comprises open countryside. This site slopes from the highest point on the south east down to the High Street.
The site is located within Flood Zone 1, with areas of Flood Zone 2 abutting the north western edge as a result of Riseley Brook. It is located outside of the settlement policy area, has been identified as a key view and forms part of the Riseley Conservation Area as outlined in the Local Plan 2030 Policy Map shown in figure 2.
[See attachment for Figure.]
Site Assessment
Optimis propose that the land between no.34 and no.36 High Street, Riseley be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity within an established, sustainable settlement.
Whilst the site is currently located outside the Settlement Policy Area, it presents a logical infill to the village well located to existing built form on three sides. Through the creation of a strong boundary on the south eastern edge the site could be contained, and any future development could easily be incorporated in to the existing pattern of development.
It is acknowledged that the site is currently allocated as an important view. Upon review of the site from High Street, the north western boundary comprises established trees and hedgerows providing comprehensive screening. This thereby limits views into the countryside significantly and potential impacts on the visibility of the landscape are not considered to be adverse. Nonetheless, further assessment of landscape impacts and consideration of these throughout the design of the scheme could be facilitated through the site’s allocation. It should also be noted that rural settlements such as Riseley have many sections where views extent into the countryside. This site is not of any great importance and its designation is not sufficient to prevent the much needed delivery of homes in sustainable locations such as this. Form this site, public footpaths extend into the wider landscape where long distance views are afforded.
It is also acknowledged that the site is located within the Riseley Conservation Area. The heavily landscaped north western boundary has the potential to provide significant screening, aiding in the mitigation of visual impacts on the Conservation Area. It is recognised that the site would still be likely to give rise to less than substantial harm on a designated heritage asset and sufficient public benefits should accompany any future scheme to outweigh this. The provision of housing on a site well related to an existing sustainable settlement in response to housing need alongside the delivery biodiversity net gain, associated contributions and further public benefits identified throughout the design process could reasonably overcome this.
Constraints identified in relation to this site are therefore not detrimental to its development and could be overcome throughout the design process to ensure the scheme is deliverable without resulting in adverse harm.
The suggested Policy wording is as follows:
[See attachment for Figure.]
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the site’s northern and southern boundary and residential development enclosed in the centre of the site’s in line with existing residential development on High Street.
[See attachment for Figure.]
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Riseley presents a logical location for development, comprising one of the most sustainable settlements in the northern area of the borough that would benefit from policy support. Additional but proportionate development in this location could be delivered quickly and provide valuable economic, social and environmental benefits to an existing community. The site outlined above presents a logical option for delivering development of this nature and should be considered by the Council for allocation alongside other extensions to existing sustainable settlement in the borough to alleviate reliance on substantial strategic site’s throughout the plan period.
Although designated in the Local Plan as an open view from the village, we consider that the scheme can be developed to retain views from the wider countryside from the southern edge of the site through the positioning of a sensitive viewpoint.